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GODDESS OF VICTORY: NIKKE

Privacy Policy

Last Updated: [October 28 ,2022]

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to the Official Website (“Website”) and Global Release for Goddess of Victory: Nikke (“Game”) on mobile version (“Mobile Version”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

For the purpose of data protection laws, the data controller of your personal information in relation to the Website and the Game is Proxima Beta Pte. Limited.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

What information do we need to be able to provide the Website and the Game?

·         If you use our Website, we will need to collect your email address or mobile phone number, device information (whether you use iOS or Android device, and device model) and IP address to allow you to pre-register for the Game.

·         If you register an account to use the Game then we will need some information from you to set this up. We will generate an open ID, which is an internal ID for your account. Depending on your use of the Game and the jurisdiction where you are based, you may also need to provide some additional information to help us set up your account.

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

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

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

More Information.

How will we use your information?

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

More Information.

Who do we share your information with?

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

·         All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game (i.e., to fulfil the purpose(s) described above).

·         In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.

More Information.

Where do we process your information?

 

·         Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

·         We have servers for the Website in Singapore and the United States and servers for the Game in Germany, Japan, Republic of Korea, Singapore and the United States. The servers applicable to your use of the Website and the Game will depend upon your location. We also have support, engineering and other teams who may support the Website and the Game, including from Singapore.

·         For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent first or taking into account adequacy assessments.

More Information.

How long do we keep your information?

·         Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Game, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.

More Information.

How can I exercise my rights over my information?

·         Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.

More Information.

How will we notify you of changes?

·         Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.

More Information.

 


Welcome to GODDESS OF VICTORY: NIKKE (Global Release)!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the the Official Website (“Website”) and Global Release of GODDESS OF VICTORY: NIKKE (“Game”) on mobile version (“Mobile Version”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

 

Please note that this Privacy Policy only applies to the Website and the Game. If you use any other products or services please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Game. By using the Game you are acknowledging how we process your personal information as described in this Privacy Policy.

 

For the purpose of data protection laws, the data controller of your personal information in relation to the Website and the Game is Proxima Beta Pte. Limited (“we”, “us”, “our”).

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

1.                Cookies

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

2.                Children

Children must not use the Website and the Game for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction). Except with such consent, children must not use the Game for any purpose. If you are a parent of a child who has signed up with your consent and you would like to understand more about the Service or how you can revoke your consent, please refer to the section “Information for Parents” below.

By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

Other than as provided above, 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 lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.

Region in which the user is located

Minimum age of the user

Argentina

13

Australia

18

Bangladesh

18

Brazil

18

Colombia

18

Cambodia

18

Canada

13

European Economic Area

16

Indonesia

21

Japan

18

Kazakhstan

18

Malaysia

18

Mexico

18

Myanmar

18

New Zealand

16

Nigeria

13

Philippines

18

Serbia

15

Singapore

13

South Africa

18

South Korea

14

Sri Lanka

18

Switzerland

16

Thailand

20

United Kingdom

13

United States

13

 

3.                How We Process Your Personal Information

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

For users who live in Brazil, the European Economic Area, Switzerland, Thailand or the United Kingdom, it also identifies the legal basis under which we process your data.

Personal Information

Use

Legal Basis (where applicable)

For the Website

Email address (all regions except Republic of Korea) or mobile phone number (Republic of Korea only)

We use this information to: 

·         allow you to pre-register for the Game;

·         notify you whether you have successfully registered for the Game; and

·         notify you when the Game becomes available for download.

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

Device information: whether you use an iOS or Android device, and device model, IP address

We use this information to: 

·         allow you to pre-register for the Game;

·         notify you whether you have successfully registered for the Game; and

·         notify you when the Game becomes available for download.

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

Email address (all regions except Republic of Korea) or mobile phone number (Republic of Korea only) (optional)

For sending news, events and promotions related to the Game.

We collect and use this information with your consent.

For Mobile Version of the Game

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

Guest log-in information: guest ID, Open ID

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

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

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, token for business

·         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 Game in accordance with your request.

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

Email delivery information: email address

We use this information to send you notifications to facilitate creation of your account for the Game (such as verification codes) and to obtain parental consent to participate in the Game (if applicable).

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

Survey information (via IMUR) (aggregated data) (Optional):

·         Via link: age, gender, income, education (optional), users' feedback on gameplay experience and gaming habits

·         In-app: age, gender, income, education (optional); users' feedback on gameplay experience and gaming habits, user ID and Open ID

We use this information to better understand our users and to improve the Game with your consent.

We collect this information with your consent.

Information generated as part of the Game

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.

IP address

We use this information to allow you to use the Game and connect to our servers.

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

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 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 Game.

In-game notifications / announcements information: Open ID

We use this information to send you in-game notifications and announcements relating to the Game.

We send you notifications about the Game with your consent.

Data monitoring information: error code, 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.  

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 Game.

It is in our legitimate interest to use this information to send you notifications about the Game.

Compliance information:

·         For email verification: Open ID, token, region, username, email

·         For credit card verification: open ID, token, region, username, credit card number, expiry date, CVC, family name, given name, email address, billing address

We use this information to verify your eligibility to participate in the Game.

Legitimate interest to ensure compliance with applicable age-gating rules.

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)

·         Game data from Unity 3D: (for Android) hashed Android ID, (for IOS) IDFV

We use this information:

·         to maintain records of log-in and user account actions;

·         to improve the Game;

·         for security and verification purposes;

·         for feedback and information about gameplay and progress; and

for tracking logged-out user preferences between apps with the same signature key and for anti-fraud purposes.

Open ID: It is in our legitimate interest to identify user logs, store Game data (including level and progress) and allow users to connect to the Game server.

IP address: Necessary for the performance of the contract, as it allows the user to connect to the Game server.

Other game data and gameplay statistics: Necessary for the performance of our contract to provide the Game.

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, IDFV

We use this information to solve crashes and optimize compatibility.

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

Chat data (free text):

Chat data: Open ID

We use this information to facilitate the posting of your communications with other users.

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

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, network delay, packet lost rate, count of android app)

We use this information for feedback and gameplay analytics to improve the Game experience.

It is in our legitimate interest to use this information to provide feedback and information about gameplay and progress.

 

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.

Payment information: Open ID, country, role ID, CPU model, device model, currency, SDK version, application version, network type, IDFV, purchase amount

 

We use this information to enable you to use the payment function in the Game.

Necessary to perform our contract with you to provide the Game, information about your purchase history and to restore purchased items.

 

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 Game (such as through anti-cheat functions).

It is in our legitimate interest to use this information to detect and prevent cheating in the Game.

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 Advertising 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

·         Firebase Installation ID generated by Firebase for each installation 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.

We use the Google Advertising ID with your consent.

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 and 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. 

It is in our legitimate interest to use this information to monitor the effectiveness of our advertisements and to provide a 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.

 

 

4.                How We Store and Share Your Personal Information

Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Website in Singapore and the United States and servers for the Game in Germany, Japan, Republic of Korea, Singapore and the United States. The servers applicable to your use of the Website and the Game will depend upon your location. We also have support, engineering and other teams who may support the Website and the Game, including from Singapore.

 

For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent first or taking into account adequacy assessments.

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

·         Third parties that provide services in support of the Website and the Game, providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Game, 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 monitoring 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 solely for the purpose of providing the Game to you.  All such group companies may only use your personal information in accordance with this Privacy Policy.

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

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

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

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

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

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

5.                The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

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

 

6.                Data Retention 

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information

Retention Policy

Website information

1 year after pre-registration is completed. If you request for deletion, data will be deleted within 7 days after your request.

Guest log-in information

Email delivery service information

XWID

Common data reporting information

Data monitoring information

Game data (including log information)

 

Analytics service (APAS) information

Data analytics to report key statistics from the processes of log-in and game updates

Security-related information

 

Payment information

Payment information (Midasbuy)

 

Data analytics to analyse user acquisition statistics

 

Compliance information

Stored for the lifetime of your use of the Game and then deleted within 1 year. If you request for account deletion, data will be deleted within 30 days after your request.

Compliance information: Credit card information will not be stored on our servers.

Social Media information (if you choose to log in via your social media account with Facebook, Google, Twitter, Line, Apple)

Open ID will be stored for the lifetime of your use of the Game and then deleted within 1 year. If you request for account deletion, data will be deleted within 30 days after your request.

Information other than Open ID will be stored for 30 days from the date you last logged into your account.

IP address

System notification information

This data is not stored on our servers.

Chat data (free text)

Online chat data is stored on your device only and is not retained on our servers.

For offline chat data, 200 entries per chat group will be stored until the offline recipient(s) log(s) back online, after which the chat data will be deleted from our cache. The retained chat data will be deleted from our cache storage within 7 days.

Account deletion information (H5)

Stored for a cool-down period of 30 days, after which it will be deleted immediately.

In-game notifications / announcements information

30 days after the notification has been delivered.

Crash information (BUGLY)

3 months.

Survey information

 

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

Customer support information (in-app, email, website)

 

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

Data analytics/profiling information (Facebook)

Stored for the lifetime of your use of the Game and then deleted within 30 days. If you request for account deletion, data will be deleted within 7 days after your request.

Data analytics/profiling information (Firebase)

 

Data analytics/profiling information (AppsFlyer)

 

Stored for up to 14 months.

Firebase Instance ID

Stored for 24 months.

 

7.                Your Rights

Some jurisdictions’ laws grant specific rights to users of the Website and the Game. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us at dpo@nikke-global.com.  

Access

You may have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. 

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.

Correction

You may have the right to correct personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account.

Erasure

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

Restriction of Processing to Storage Only

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

Objection

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

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at dpo@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. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

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

8.                Contact

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

Email: dpo@nikke-global.com

Mailing Address:

Tencent International Privacy & Data Protection Centre

30 Raffles Place #19-01

Singapore

048622

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

9.                Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

10.            Language

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


INFORMATION FOR PARENTS – GLOBAL RELEASE

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

 

What personal information does the Game process?

 

The Game is a mobile game.

 

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

 

·         Age and IP address.

·         Log-in information: Open ID, and other information if relevant, such as email address.

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

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

·         Game data, crash and analytics information.

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

 

 

Does the Game process personal information differently for children?

 

Children will not be able to access the free chat function and can only communicate using the quick chat function by selecting pre-set text messages.

 

Why is my consent required?

 

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

 

 

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

 

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

 

 

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

 

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

 

 

Will you retain my personal information?

 

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

 

 

What if I do not consent?

 

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

 

 

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

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

 

 


Our Representatives in Certain Jurisdictions

Jurisdiction

Representative

Address

Contact details

EU

Proxima Beta Europe B.V.

Buitenveldertselaan 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

Korea

Kite Bird Korea Yuhan Hoesa

 

25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea

dpo@nikke-global.com

Serbia

Karanovic & Partners o.a.d. Beograd

Resavska 23, Belgrade, 11000, Serbia

local.representative@karanovicpartners.com

 

Thailand

Tencent (Thailand) Company Limited

T-One Building, Bangkok, Thailand

dpo@nikke-global.com

 


SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Website and the Game, 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.

Argentina

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar). While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing your personal information and by using the Website and the Game, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Australia

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

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game, and the Website.

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

 

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

Bangladesh

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

Brazil

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

 

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

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:

 

We collect your personal information for the following purposes:

 

For additional information about what each type of personal information is used for, see Section 2 (How We Process Your Personal Information).

 

We disclose personal information to the following types of entities:

 

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:

 

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 8 (Contact).

Canada

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

Colombia

Your authorization to process personal information for the Website and the Game may be expressed (i) in writing, (ii) orally or (iii) through unequivocal conduct that allows us to reasonably conclude that your authorization has been granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

 

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information. You can contact us to exercise any of these rights, using the information specified in Section 8 (Contact)

 

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 8 (Contact).

Indonesia

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

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game, and the Website.

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

If you fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen (14) days of the date the relevant amended version of this Privacy Policy is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy. However, you may stop using or accessing our Website and Game by unsubscribing or ceasing your use of the Website and Game at any time, if you cease to agree with the amended Privacy Policy.

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

Japan

If you are under the age of 18, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Game and the Website.

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

 

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

 

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

Kazakhstan

If you are under the age of 18, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Game and the Website.

By clicking “accept”, you consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information as described in this Privacy Policy. The transfer of your personal information to third parties, which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore and the United States.

 

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

Your Rights

 

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

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

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

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

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

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

Malaysia

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Game and the Website, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

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

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However, this may affect our provision of the Website and the Game to you.

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

Mexico

Some of the purposes of processing specified in Section 2 (How We Process Your Personal Information) are voluntary. We may also use your personal data for the voluntary purpose of sending information to your email that we may consider relevant to you.

In general, we do not require your consent to carry out the transfers detailed in Section 4 (How We Store and Share Your Personal Information). In any case, by using the Website and the Game and providing us with your personal data, you agree to the data transfers detailed therein that require your consent.

To understand more about and exercise your rights to “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us as specified in Section 8 (Contact).

New Zealand

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

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

If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game and the Website.

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

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

Peru

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

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

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

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

Philippines

You are entitled to the following rights:

 

By consenting to this Privacy Policy, you consent to us:

Republic of Korea

We provide your personal information to third parties as described below:

Name of Recipient (and contact information)

Types of Personal Information provided

Purpose of Use by Recipient

Period of Retention and Use by Recipient

Appsflyer  Limited

(privacy@appsflyer.com)

Advertising information

User acquisition purposes and to monitor the effectiveness of our advertisements

For the data retention period specified under “Data Retention

Facebook Analytics

https://www.facebook.com/help/contact/507739850846588

Contact information, event data and hashed data

User acquisition purposes and to monitor the effectiveness of our advertisements

For the data retention period specified under “Data Retention

Google Analytics (Firebase)

https://firebase.google.com/support

 

 

Analytics data

Data analytics

For the data retention period specified under “Data Retention

 

For the performance of the services detailed in this Privacy Policy, we delegate the processing of your personal information to the following professional service providers:

Delegatee

Description of Delegated Services

Midas

Provide payment function

Adyen N.V.

(dpo@adyen.com )

Process credit card payment for verifying parental consent

AIHelp (ShareFun Network Limited)

(privacy@aihelp.net )

Process information to provide customer service to users

Aceville Pte Ltd

(cloudlegalnotices@tencent.com)

Storage of personal information

Tencent Cloud LLC

(
cloudlegalnotices@tencent.com)

Storage of personal information

Amazon Web Services Inc. (USA)

(https://aws.amazon.com/privacy/)

Storage of personal information

Microsoft Azure

Data security

 

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

Recipient (Contact Information of Information Manager)

Country to which Your Personal Information is to be Transferred

Date and Method of Transfer

Types of Your Personal Information to be Transferred

 

Purposes of Use by Recipients

Period of Retention of Use by Recipient

Tencent Cloud LLC

(
cloudlegalnotices@tencent.com)

United States

Transmitted from time to time

All personal information collected

Storage of personal information

For the data retention period specified under “Data Retention

Amazon Web Services Inc. (USA)

(https://aws.amazon.com/privacy/)

United States

Transmitted from time to time

All personal information collected

Storage of personal information

For the data retention period specified under “Data Retention

 

Aceville Pte Ltd

 

(cloudlegalnotices@tencent.com)

 

Singapore

Transmitted from time to time

All personal information collected

Storage of personal information

For the data retention period specified under “Data Retention

Midas

United States

Transmitted from time to time

Information regarding payment on Midasbuy Platform

Payment

For the data retention period specified under “Data Retention

Google Analytics (Firebase)

(https://firebase.google.com/support)

United States unless otherwise described in the service provider’s privacy policy

Transmitted from time to time

Analytics data

Data analytics

For the data retention period specified under “Data Retention

Facebook (Analytics)

(https://www.facebook.com/help/contact/507739850846588)

 

United States unless otherwise described in the service provider’s privacy policy

Transmitted from time to time

Contact information, event data and hashed data

Re-targeting marketing to train algorithm to find high potential target audience

For the data retention period specified under “Data Retention

Appsflyer Limited

(privacy@appsflyer.com)

Dublin, Ireland hosted by AWS and in St. Ghislain, Belgium hosted by Google Cloud, United States

Transmitted from time to time

Advertising information

To monitor the success of our advertising and marketing programs

For the data retention period specified under “Data Retention

Adyen N.V.

 

(dpo@adyen.com )

The Netherlands

Singapore

Transmitted from time to time

Payment card information

For verifying payment card information in relation to parental/guardian consent

For the data retention period specified under “Data Retention

AIHelp (ShareFun Network Limited)(privacy@aihelp.net )

Texas, United States

Transmitted from time to time

Customer support information

To provide you with customer support services

For the data retention period specified under “Data Retention

 

Microsoft Azure

United States

Transmitted from time to time

Data Security information

Data security

For the data retention period specified under “Data Retention

 

 

Data Destruction

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

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

 

Act on the Consumer Protection in Electronic Commerce, Etc.

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

In an electronic commerce or a mail-order sale:

·         Records regarding labelling and advertising (6 months)

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

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

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

Protection of Communications Secrets Act

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

·         Log records, IP address (3 months)

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

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

Additional Use and Provision of Personal Information

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

 

Domestic Privacy Representative

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

Contact

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

 

Website - Mandatory Consent language

Mandatory Consents

To provide you with the GODDESS OF VICTORY: NIKKE Website, we will need to collect, access, process and use the following personal information. You have the right to refuse, but if you refuse, you will not be able to register your interest on the GODDESS OF VICTORY: NIKKE Website. Do you agree to our collection and use of the following personal information?

Items to be Collected

Mobile phone number, device information (whether you use an iOS or Android device, and device model) and IP address.

Purpose of Collection and Use

To provide you with updates and notify you when the GODDESS OF VICTORY: NIKKE Global Release becomes available for download and to allow you to redeem your gift once GODDESS OF VICTORY: NIKKE is officially launched.

Period of Retention and Use

1 year after pre-registration is completed. If you request for deletion, data will be deleted within 7 days after your request.

 

 

 

Website - [Mandatory] Overseas transfers of my personal information

Recipient (Contact Information of Information Manager)

Country to which Your Personal Information is to be Transferred

Date and Method of Transfer

Types of Your Personal Information to be Transferred

 

Purposes of Use by Recipients

Period of Retention of Use by Recipient

Tencent Cloud LLC

(
cloudlegalnotices@tencent.com)

United States

Transmitted from time to time

Phone number

Sending of invitation links to the Global Release

For the data retention period specified under “Data Retention

 

Website - [Mandatory] Third party provision of personal information

Recipient (Contact Information of Information Manager)

Country to which Your Personal Information is to be Transferred

Date and Method of Transfer

Types of Your Personal Information to be Transferred

 

Purposes of Use by Recipients

Period of Retention of Use by Recipient

Tencent Cloud LLC

(
cloudlegalnotices@tencent.com)

United States

Transmitted from time to time

Phone number

Sending of invitation links to the Global Release

For the data retention period specified under “Data Retention

 

Website - [Optional] Consent to Collection and Use of Personal Information for SMS Marketing Consent

Optional - Marketing Consent

 

Proxima Beta Pte. Limited would like to collect and use your mobile phone number to provide you updates and send you news, events and promotions related to GODDESS OF VICTORY: NIKKE. By ticking the box, you represent that you agree to the collection and use of the following personal information for the purpose of receiving news, events and promotions related GODDESS OF VICTORY: NIKKE via SMS in accordance with the Privacy Policy [insert link].

 

You have the right to refuse consent; however, if you refuse, you will not receive news, events and promotions.

 

·         Items to be Collected: Mobile phone number. 

·         Purpose of Collection and Use: To send you news, events and promotions related to GODDESS OF VICTORY: NIKKE.

·         Period of Retention and Use: 1 year after pre-registration is completed. If you request for deletion, data will be deleted within 7 days after your request.

 

 

Mandatory Consent language

Mandatory Consents

To provide you with the GODDESS OF VICTORY: NIKKE Global Release (GR), we will need to collect, access, process and use the following personal information. You have the right to refuse, but if you refuse, you will not be able to register for the GODDESS OF VICTORY: NIKKE (GR). Do you agree to our collection and use of the following personal information?

 

Items to be Collected

·         Guest log-in information: Guest ID, Open ID

·         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, token for businessVia 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

·         Email delivery information: Email address

·         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

·         XWID: Your XWID, which is generated by us

·         IP address

·         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 ROM, system language

·         In-game notifications / announcements information: Open ID

·         Data monitoring information: error code, error message,  SDK name, SDK version, request URL, response body, sequence ID, stage, log, common information for data reporting

·         System notification information: device token and FCM (Firebase Clous Message) token

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

·         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), game data from Unity 3D: For iOS: IDFV

·         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, IDFV

·         Chat data (free text): chat data, Open ID

·         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, network delay, packet lost rate, count of android app)

·         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

·         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

·         Account Deletion information (H5): email address, region, Open ID, user token

·         Payment information: Open ID, country, role ID, CPU model, device model, currency, SDK version, application version, network type, IDFV, purchase amount

·         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)

·         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 Advertising 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; Firebase Installation ID generated by Firebase for each installation will be processed by Appsflyer

·         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 and Open ID.

Purpose of Collection and Use

·         Guest log-in information, social media information: to create your account for the Game in accordance with your request.

·         Email delivery information: to send you notifications to facilitate creation of your account for the Game (such as verification codes) and to obtain parental consent to participate in the Game (if applicable).

·         Customer support information (in app, email, website): to provide support and troubleshooting, such as addressing and remediating technical issues and bugs, and improve our services.

·         XWID: for guest login and debugging.

·         IP address: to allow you to use the Game and connect to our servers.

·         Common data reporting information: for data analytics purposes.

·         In-game notifications / announcements information: to send you in-Game notifications and announcements relating to the Game.

·         Data monitoring information: to fix bugs, and to understand the performance and interaction of our SDKs.

·         System notification information: to provide you with notifications on your device about the Game.

·         Compliance information: to verify your eligibility to participate in the Game.

·         Game data (including log information): to maintain records of log-in and user account actions, to improve the Game, for security and verification purposes, for feedback and information about gameplay and progress, and for tracking logged-out user preferences between apps with the same signature key and for anti-fraud purposes.

·         Crash information (BUGLY): to solve crashes and optimize compatibility.

·         Chat data (free text): to facilitate the posting of your communications with other users.

·         Analytics service (APAS) information: for feedback and gameplay analytics to improve the Game experience.

·         Data analytics/profiling information (Facebook): for user acquisition purposes and to monitor the effectiveness of our advertisements.

·         Data analytics to report key statistics from the processes of log-in and game updates: to understand the success rate of the log-in and update process.

·         Account Deletion information (H5): to allow you to delete your account upon your request.

·         Payment information: to enable you to use the payment function in the game.

·         Security-related information: to ensure the security and safety of the services of the Game (such as through anti-cheat functions).

·         Data analytics/profiling information (Appsflyer): for ad attribution.

·         Data analytics/profiling information (Firebase): for app performance analytics. We use the Firebase Instance ID to increase in-Game purchase rates of new users through Google platforms. 

Period of Retention and Use

·         Guest log-in information, Email delivery service information, XWID, Common data reporting information, Data monitoring information, Game data (including log information), Analytics service (APAS) information, Data analytics to report key statistics from the processes of log-in and game updates, Security-related information, Payment information; Compliance information: Stored for the lifetime of your use of the Game and then deleted within 1 year. If you request for account deletion, data will be deleted within 30 days after your request.

·         Chat data: Online chat data is stored on your device only and is not retained on our servers. For offline chat data, 200 entries per chat group will be stored until the offline recipient(s) log(s) back online, after which the chat data will be deleted from our cache. The retained chat data will be deleted from our cache storage within 7 days.

·         Social media information (if you choose to log in via your social media account with Facebook, Google, Twitter, Line, Apple):  Open ID will be stored for the lifetime of your use of the Game and then deleted within 1 year. If you request for account deletion, data will be deleted within 30 days after your request. Information other than Open ID will be stored for 30 days from the date you last logged into your account.

·         IP address, System notification information: Not stored on our servers.

·         Account deletion information (H5): Stored for a cool-down period of 30 days, after which it will be deleted immediately.

·         In-game notifications / announcements information: Stored for 30 days after the notification has been delivered.

·         Crash information (BUGLY): Stored for 3 months.

·         Customer support information (in-app, email, website): Stored for 2 years. If you request for deletion, data will be deleted within 30 days after your request.

·         Data analytics/profiling information (AppsFlyer); Data analytics/profiling information (Firebase): Stored for up to 14 months.

·         Data analytics/profiling information (Facebook): Stored for the lifetime of your use of the Game and then deleted within 30 days. If you request for account deletion, data will be deleted within 7 days after your request

·         Firebase Instance ID: Stored for 24 months.

 

 

 

Notifications / Electronic transmissions / Surveys

Optional Consents

Certain features of the GODDESS OF VICTORY: NIKKE Global Release (GR) require us to collect and use the following personal information. You have the right to refuse, but if you refuse, certain features of GODDESS OF VICTORY: NIKKE GR may be unavailable.

 

You represent that you agree to the collection and use of the following personal information for the purpose of sending you reoccurring in-Game notifications and announcements via automated messaging, and for the purposes of carrying out surveys about the GR.

 

We may send a reasonable number of game updates and other non-promotional messages. You understand that choosing to receive these messages is not required to purchase products or services from Proxima Beta. We note that you have the right to refuse to give your consent, but you may not be able to receive useful information regarding updates if you refuse.

 

Items to be Collected

·         In-game notifications / announcements information: open ID

·         System notification information: device token and FCM (Firebase Cloud Message) token

·         Survey information (via IMUR) (aggregated data): 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

Purpose of Collection and Use

·         In-game notifications / announcements information: to send you in-game notifications and announcements relating to the GR.

·         System notification information: to provide you with notifications on your device about the GR.

·         Survey information (via IMUR) (aggregated data): to better understand our users and to improve the Game with your consent.

Period of Retention and Use

·         In-game notifications / announcements information: Stored for 30 days after the notification has been delivered.

·         System notification information: Not stored on our servers.

·         Survey information (via IMUR) (aggregated data): 1 year.

 

Serbia

Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.

Singapore

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

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

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

South Africa

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

Sri Lanka

By clicking “accept”, you consent to the Privacy Policy and permit the collection, use and disclosure of your personal information. However, if you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game and the Website.

Thailand

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

 

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

 

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

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

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

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

·         lodge a complaint to a relevant authority.

 

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

 

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

Ukraine

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries other than Ukraine, to the extent and for the purpose provided by this Privacy Policy.