Welcome to GODDESS OF VICTORY: NIKKE (Recruitment Website and Closed Beta Test)!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information when you register your interest to participate in the mobile version of GODDESS OF VICTORY: NIKKE (the “Game”) Closed Beta Test (“CBT”) through the recruitment website (“Recruitment Website”), and when you participate in the CBT, and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information through the Recruitment Website and do not participate in the CBT. By providing your details through the Recruitment Website and/or participating in the CBT you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

This Recruitment Website and CBT have been developed by Proxima Beta Pte. Limited (“we”, “us”, “our”).

For the purpose of data protection laws, the data controller of your personal information in relation to the Recruitment Website and CBT is Proxima Beta Pte. Limited, which is a member of our corporate group. The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore.

Our data protection officer can be contacted at dpo@nikke-global.com.

Our representatives for data protection purposes in certain jurisdictions are as follows:

Jurisdiction	Representative	Address	Contact details
EU	Proxima Beta Europe B.V.	Buitenveldertselaan 3-5 1082 VA Amsterdam	dpo@nikke-global.com
UK	Image Frame Investment (UK) Limited	Suite 1, 3rd Floor 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB	dpo@nikke-global.com
Thailand	Tencent (Thailand) Limited	T-One Building, Bangkok, Thailand	dpo@nikke-global.com

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. You can contact us anytime at dpo@nikke-global.com.

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How We Use Your Personal Information” below.

The following is a high-level summary of the types of personal information we use:

Recruitment Website

If you register your interest to participate in the CBT for the Game through the Recruitment Website, we will collect your email address, device information (whether you use an iOS or Android device, and device model), IP address, and your gaming habits. We use this information to share your email address with Google and/or Apple to send you a link and invite you to participate in the CBT for the Game.

CBT

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

· Account registration information: you give us information about you when you set up an account to register for the CBT, including your Guest ID.

· Account registration information (via social media accounts): when you choose to log into the CBT with your social media account (Facebook, Google, Twitter, Line and Apple), we import information from your connected social media account in order to set up your profile. This will include your user ID, nickname, profile picture, user token and open ID.

· Email delivery service: your email to send you notifications to facilitate creation of your account (such as verification codes) and to obtain parental consent to participate in the CBT (if applicable);

· Customer support and feedback information: relevant information that you voluntarily provide to us when you communicate with our customer service, when you give us reviews or feedback or otherwise provide information to us through the CBT.

· Survey information: if you choose to participate in a survey about the CBT via a link or in app, you may be asked to provide certain personal information, such as your age, gender, income, education (optional), your feedback on gameplay experience, user ID and open ID (for in-app survey), and any other content you choose to provide as part of the survey response.

b. Information about you generated as part of the CBT

We automatically collect certain data from you when you use the CBT, namely:

· XWID: your XWID for debugging purposes and to allow you to use guest log-in;

· Data reporting information: data reporting information to perform analytics;

· In-game notifications / announcements: your open ID to send you notifications and announcements in-app for system updates and game events;

· Data monitoring information: error code, error message, SDK name and version, request URL, response body, sequence ID, stage, log, and common information for data reporting, to fix bugs and understand how well our SDKs interact and invoke other SDKs;

· System notification information: device token and Firebase Cloud Message token, to provide you with system updates and game events;

· Game data (including log information): game data information such as your open ID, IP address, role ID, game account, user nickname, country code, device information, and gameplay statistics;

· Crash information (BUGLY): to locate and solve crash issues;

· Analytics service (APAS): your user region and device information to provide feedback and information about your gameplay and progress;

· Data analytics/profiling (Appsflyer): technical information, technical identifiers and engagement information for ad attribution;

· Data analytics/profiling (Firebase): user device dimensions and in-app events for app performance analytics; and your Firebase instance ID and open ID to increase in-game purchase rates of new users through Google platforms in our games;

· Data analytics/profiling (Facebook): your contact information and event data for marketing and advertising purposes;

· Data analytics information: data analytics information to report key statistics from log-in and game updates;

· Customer support information (in app, email, website): various device information and details of your request and handling;

Account deletion information (H5): your email address, region, open ID, and user token to allow you to delete your user account upon your request; and

Security-related information: various security-related information for anti-cheating purposes.

2. Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Recruitment Website. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.

For more information about our Cookies policy, click here.

3. Children

Children must not use the Recruitment Website and CBT for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your region).

By children, we mean users under the ages listed in the table below.

Region in which the user is located	Minimum age of the user
France	15
Germany	16
Thailand	20
United Kingdom	13
United States	13

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo@nikke-global.com and we will delete such information.

4. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the France, Germany, Thailand or United Kingdom (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (only relevant if you are located in a Relevant Jurisdiction)
Recruitment Website
Email address, device information (whether you use an iOS or Android device, and device model), IP address, and your gaming habits.	We use this information to notify you when the CBT becomes available for download and to allow you to redeem your gift once the Game is officially launched.	Necessary to perform our contract with you to provide with a link to the CBT and to allow you to redeem your gift once the Game is officially launched.
CBT
Information you provide to us (either directly or through a third party)
Guest log-in information: Guest ID	We use this information to create your account for the CBT in accordance with your request.	Necessary to perform our contract with you to provide the CBT.
Social Media information (if you choose to log in via your social media account with these networks): · Via Facebook: Name, Facebook UID, name, profile picture, user token, open ID · Via Google: Google user ID, nickname, profile picture, user token, open ID · Via Twitter: Twitter user ID, nickname, profile picture, user token, open ID · Via Line: Line user ID, nickname, profile picture, user token, open ID · Via Apple: Apple user ID, nickname, profile picture, user token, open ID	We use this information to create your account for the CBT in accordance with your request.	Necessary to perform our contract with you to provide the CBT.
Email delivery information: Email address	We use this information to send you notifications to facilitate creation of your account for the CBT (such as verification codes) and to obtain parental consent to participate in the CBT (if applicable).	Necessary to perform our contract with you to provide the CBT and send verification codes.
Customer support information (in app, email, website): · Via app: name, open ID, device model, application version, battery level, Wifi strength, free space on phone, network type, iOS version, platform, carrier, country code, photo to illustrate problem (optional) · Via website: name, open ID, device model, email address (optional) · Via email: name, email address · For all: details of ticket, complaint and handling	We use this information to provide support and troubleshooting, such as addressing and remediating technical issues and bugs, and improve our services.	Necessary to perform our contract with you to provide the CBT.
Survey information (via IMUR) (aggregated data) (Optional): · Via link: age, gender, income, education (optional), users' feedback on gameplay experience · In-app: age, gender, income, education (optional); users' feedback on gameplay experience, user ID and open ID	We use this information to better understand our users and to improve the Game with your consent.	Consent.
Information generated as part of the CBT
XWID: Your XWID, which is generated by us	We use this information for guest login and debugging.	It is in our legitimate interest to use this identifier for guest login and debugging.
Common data reporting information: game ID, client source, session ID, event time, client IP, country, province, city, carrier ID, open ID, event name, OS, OS version, SDK version, network type, bundle ID, app version, login channel ID, device model, device brand, screen width, screen height, CPU name, CPU core, CPU frequency, GPU name, total RAM, total ROM, system language	We use this information for data analytics purposes.	It is in our legitimate interest to use this information for game analytics purposes to monitor the operation of the CBT.
In-game notifications / announcements information: open ID	We use this information to send you in-game notifications and announcements relating to the CBT.	It is in our legitimate interest to use this information to send you notifications about the CBT.
Data monitoring information: errorcode, error message, SDK name, SDK version, request URL, response body, sequence ID, stage, log, common information for data reporting	We use this information to fix bugs, and to understand the performance and interaction of our SDKs.	It is in our legitimate interest to use this information to fix bugs and monitor the performance of our SDKs.
Compliance information: OpenID, token, region, username, email	We use this information to verify your eligibility to participate in the CBT.	Legitimate interest to ensure compliance with applicable age-gating rules.
System notification information: device token and FCM (Firebase Cloud Message) token	We use this information to provide you with notifications on your device about the CBT.	It is in our legitimate interest to use this information to send you notifications about the CBT.
Game data (including log information): · Open ID · IP address · Role ID, game account, user nickname, country code, device system version, device brand, IDFV, device model, device manufacturer, device name, screen resolution, screen orientation, CPU model, GPU information, RAM, client exports IP, phone memory, login channel ID, operator name, network type, signal strength, and buried data reporting · Gameplay statistics (including player level and in-game performance)	We use this information: · to maintain records of log-in and user account actions, · to improve the Game, · for security and verification purposes, and · for feedback and information about gameplay and progress.	Open ID: Legitimate interests to identify user logs, store Game data (including level and progress) with user's profile and allow the user to connect to the CBT server. IP address: Necessary for the performance of the contract, as it allows the user to connect to the CBT server. Other game data and gameplay statistics: Necessary for the performance of our contract to provide the CBT.
Crash information (BUGLY): · For Android: device name, device model, phone memory, CPU usage rate, CPU model, device system version, device brand, ROM, RAM, CPU architecture, Root status, remaining external SD card space, remaining memory, whether simulator is used, running process information, system time, XWID, process name, network type, application version, application package name, SDK version, SDK version number / application name and version number · For iOS: device name, device model, phone memory, CPU usage rate, CPU model, device system version, ROM, RAM, CPU architecture, Root status, remaining memory, whether simulator is used, running process information, system time, process name, network type, application version, application package name, SDK version, SDK version number / application name and version number	We use this information to solve crashes and optimize compatibility.	It is in our legitimate interest to use this information to ensure the security of the CBT.
Analytics service (APAS) information: User region (country, province, city, carrier ID, region, IP address); device information (application version, application ID, battery information, WiFi strength, available space, network type, OS version, OS name, carrier, country code, device language, device resolution, brand, manufacturer, device model, RAM, ROM and CPU information, GPU information, game frame information, mobile signal strength, network round trip time, network bytes received/sent, login/pay step event information, XWID)	We use this information for feedback and game and gameplay analytics to improve the gameplay experience.	It is in our legitimate interest to use this information to provide feedback and information about gameplay and progress.
Data analytics/profiling information (Appsflyer): · Technical information: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier · Technical Identifiers: IP address, user agent, IDFA, Google Advertiser ID, Open ID · Engagement Information: clicks on customer ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, the webpages on customer’s website visited by an end user, the URL from the referring website, downloads and installations of applications, and other interactions, events and actions customers choose to measure and analyse within their application or website (e.g. add to cart, in-app purchases made, clicks, engagement time etc.) Firebase Instance ID generated by Firebase and open ID will be processed by Appsflyer	We use this information for ad attribution.	It is in our legitimate interest to carry out data analytics and profiling for ad attribution purposes to understand how our users interact with advertisements. It is in our legitimate interest to use the Firebase Instance ID to increase in-game purchase rate of new users through Google platforms.
Data analytics/profiling information (Firebase): · Default Firebase implementation collects: User device dimensions and in-app events such as number of users and sessions, session duration, operating systems, device models, geography, first launches, app opens, app updates, in-app purchases · Firebase collects the following device dimensions: age, App Store, app version, country, device brand, device category, device model, first open time, gender, interests, language, new/established, OS version · Firebase automatically collects the following in-app events: advertising analytics such as ad clicks, ad exposure, ad impression, ad query, ad exposure, application analytics such as app usage, app clearance, app crashes, app removal, app payment analytics, app update and use analytics, website usage analytics, such as web clicks, browser downloads, notification, video progress, search analytics · Ad ID and IDFA · Firebase Instance ID open ID	We use this information for app performance analytics. We use the Firebase Instance ID to increase in-game purchase rates of new users through Google platforms in our games.	It is in our legitimate interest to use this information to monitor the effectiveness of our advertisements so as to provide better gaming experience.
Data analytics/profiling information (Facebook): · Contact Information: name, email address, and phone numbers · Event Data: information, such as site visits, app installations, products purchase, information collected and transferred when people access a website or app with Facebook Login or Social Plugins (e.g. the Like button). It does not include information created when an individual interacts with our platform via Facebook Login, Social Plugins · Hashed Data: including personal data such as email addresses and phone numbers	We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements.	It is in our legitimate interest to use this information to monitor the effectiveness of our advertisements so as to provide better gaming experience.
Data analytics to report key statistics from the processes of log-in and game updates: event name, stage number, stage name, stage status, stage error code, extra json, stage time	We use this information to understand the success rate of the log-in and update process.	It is in our legitimate interest to use this information to understand the success rate of the log-in process (and where users drop out), as well as the update process (whether the game update process is successful).
Account Deletion information (H5): email address, region, open ID, user token	We use this information to allow you to delete your account upon your request.	Necessary to perform our contract with you to delete your account upon your request.
Security-related information: list of hack or cheating software, in-game screen information, device operation system settings, device information including mobile phone brand, model, CPU structure, CPU model, kernel version, resolution, application package of hack software, available memory, wifi access point, list of installed APK and running apps, jailbreak status (iOS)	We use this information to ensure the security and safety of the services of the CBT (such as through anti-cheat functions).	It is in our legitimate interest to use this information to detect and prevent cheating in the CBT.

5. How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide you with the CBT, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy.

Recruitment Website: Your data will be stored in the United States.

CBT: Your information will generally be stored in the United States. If you are located in the United Kingdom, Germany, France or Thailand your Game data (including log information) will be processed in Germany before it is stored in the United States. If you are located in the United States your Game data (including log information) will be stored in the United States.

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Third parties that provide services in support of the Recruitment Website and CBT, including to send you a link to allow you to sign up to the CBT for the Game, providers of cloud services that process information identified in this policy on their servers for the purpose of providing the CBT, for the purpose of processing support ticket ID and support communication, for the purpose of processing gameplay and game rendering data to provide game analytics to improve gameplay, and for the purpose of providing marketing and advertisements and monitor the success of our marketing and advertising programs. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

· Companies within our corporate group who process your personal information in order to operate the Recruitment Website and CBT, and conduct surveys of the CBT for us. All related group companies may only use your personal information in accordance with this Privacy Policy.

· Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

· A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

6. The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Recruitment Website or CBT or otherwise via the Internet; any transmission is at your own risk.

7. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
Recruitment Website
Recruitment Website information	Email will be stored for one year after the end of the CBT. All other information will be stored for the lifetime of the CBT and then deleted within 30 days. If you request for deletion, data will be deleted within 7 days after your request.
CBT
XWID Guest log-in information Social Media information (if you choose to log in via your social media account with Facebook, Google, Twitter, Line, Apple) Common data reporting information Data monitoring information Compliance information Game data (including log information) Email delivery service information Crash information (BUGLY) Analytics service (APAS) information Data analytics to report key statistics from the processes of log-in and game updates Security-related information Data analytics/profiling information (Firebase) Data analytics/profiling information (AppsFlyer)	Stored for the lifetime of the CBT and then deleted within 30 days. If you request for deletion, data will be deleted within 7 days after your request.
Customer support information (in-app, email, website)	Stored for the lifetime of the CBT and then deleted within 30 days. If you request for deletion, data will be deleted within 30 days after your request.
In-game notifications / announcements information	Stored for 30 days after the notification has been delivered. If you request for deletion, data will be deleted within 7 days after your request.
System notification	This data is not stored on our servers.
Firebase instance ID reporting function Data analytics/profiling information (Facebook)	Stored for the lifetime of the CBT and then deleted within 30 days. If you request for deletion, data will be deleted within 30 days after your request.
Account deletion information (H5)	Stored for a cool-down period of 30 days, after which it will be deleted immediately.
Survey information	1 year.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

8. Your Rights

This section entitled “Your Rights” applies to users that are located in a Relevant Jurisdiction. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

The sub-section entitled “Advertising” also apply to users that are located in the United States.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at dpo@nikke-global.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo@nikke-global.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Process Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Recruitment Website and CBT account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo@nikke-global.com.

Erasure

You can delete your account, or remove certain personal information, by logging into your Recruitment Website and CBT account. If there is any other personal information you believe we process that you would like us to erase, please contact us at dpo@nikke-global.com.

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

Restriction of Processing to Storage Only

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

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at dpo@nikke-global.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at dpo@nikke-global.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

9. Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Recruitment Website and/or CBT for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

10. Advertising

You may choose to stop receiving personalised advertising or marketing promotions from us when using the CBT by contacting us at dpo@nikke-global.com.

11. Contact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo@nikke-global.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo@nikke-global.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the region in which you live or work where you think we have infringed data protection laws.

12. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

13. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Recruitment Website and CBT, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

Identifiers, such as your name as it appears on your social media profile, Open ID / user ID, IP address, device ID, device token, phone number, mailing address, email address, and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.
Internet or other electronic network activity information, such as your information regarding your use of the Recruitment Website and CBT, including level, score, date and time stamps of actions, log-in and clickstream data and other Device Information as described in the main Privacy Policy. This information is collected directly from you and your device.
Other information described in subdivision (e) of Section 1798.80, including information about your gender, nationality, or age. This information is collected directly from you in the context of being our consumer.

We collect your personal information for the following purposes:

To provide you with the Recruitment Website and CBT, maintain your account and provide customer service.
To process surveys.
To improve our services, including the functionality of the Recruitment Website and CBT.
For security and verification purposes, including to prevent and detect anti-cheating behaviour.
To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see Section 4 (How We Process Your Personal Information).

We disclose personal information to the following types of entities:

Other companies within our corporate group who process your personal information in order to operate the Recruitment Website and CBT.
Other companies that provide services on our behalf in support of the Recruitment Website and CBT and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
Regulators, judicial authorities and law enforcement agencies
Entities that acquire all or substantially all of our business.

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

Rights under the CCPA:

If you are a California resident, you have the right to:

Request we disclose to you free of charge the following information covering the 12 months preceding your request:

the categories of personal information about you that we collected;
the categories of sources from which the personal information was collected;
the purpose for collecting personal information about you;
the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
the specific pieces of personal information we collected about you;

Request we delete personal information we collected from you, unless CCPA recognises an exception; and
Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 11 (Contact).

France

Instructions for the processing of your personal data after your death. You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us as set out in Section 11 (Contact).

Thailand

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us as set out in Section 11 (Contact).