GODDESS OF VICTORY: NIKKE

Privacy Policy

Last Updated: 4 July 2024

Thank you for using Proxima Beta’s 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 for Goddess of Victory: Nikke (“Game”) on the PC version (“PC Version”), mobile version (“Mobile Version”) and website version (“Website 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. If you register for a LEVEL INFINITE PASS Account, this includes a username and email address. 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, Japan, Korea, Malaysia and the People’s Republic of China. · 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!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the Official Website (“Website”) and GODDESS OF VICTORY: NIKKE (“Game”) on the PC version (“PC Version”), mobile version (“Mobile Version”) and website version (“Website 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
Australia	18
Brazil	18
Colombia	18
Cambodia	18
Canada	13
European Economic Area	16
Japan	18
Mexico	18
New Zealand	16
Philippines	18
Singapore	13
South Africa	18
South Korea (Mobile and Website)	14
South Korea (PC)	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
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.
Email address (processed by LEVEL INFINITE PASS if you choose to log in via your LEVEL INFINITE PASS account and participate in Game events) LEVEL INFINITE PASS’s privacy policy can be found at: https://account.levelinfinite.com/privacypolicy.html		If you participate in Game events, we use this information to distribute rewards.	Necessary to perform our contract with you to provide the Game event.
Account deletion information (Website): country/region, contact name, nickname, user id, email address, server, level		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.
For the PC Version, Mobile Version and Website 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.
LEVEL INFINITE PASS Account log-in information (if you choose to log-in via LEVEL INFINITE PASS Account): UID, token, email, username https://account.levelinfinite.com/privacypolicy.html	We use this information to link your game account to your LEVEL INFINITE PASS Account in accordance with your request.		Necessary to perform our contract with you to provide the Game.
Hashed Nickname	If your account is determined to breach our Terms of Service or otherwise is found to be undertaking activity which is illegal, defamatory, damaging to the platform or similar, and your account is consequently suspended, we may publish a hashed version of your nickname on our Website and in the Game (including via in-Game pop-up).		It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game, including notifying other players if a participant has been removed for behaviour that violates the Terms of Service.
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: · Game user account and contact information (including your user nickname and icon, open ID, APPID, country selected by you during registration, login channel and channel ID, registered username, social account, mobile phone, registration time, level, email address and email verification code); · Login status verification information; · Device information; · Game data: Game character information (including your role name and role ID, game data and records, frequency of playtime, game history), and in-game data (including items, purchase and top-up information, penalties, activities, game match data, in-game friends); · Device information such as device ID and IP address (only applicable for guest users that have lost their account); · Customer service log data (including Open ID, ticket date, type of request); · Any other details/information (including any documents/media) that you choose to provide to us as part of your ticket, query or review, and your contact information.	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.
User Report Information: information of reporting user and reported user, report descriptions, game match data, punishment or gaming restrictions, in-game chat information (to the extent raised in relation to the report), report processing time, report processing results and reasons	We use this information to review reports and complaints, and determine whether reported users have cheated in the Game or otherwise violated the Terms of Service.		It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within 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.
Crash- related information For mobile version: user IDs, IDFV, device identifiers, device information, storage, network status, logs, startup time, IP country location, exception information For PC version: user IDs, PC mac address, operating system name, graphic card name, machine memory, resolution, startup time, device identifiers, IP country location, exception information, CPU, GPU and system information, storage, network status, log	We use this information to locate and resolve crash issues.		It is in our legitimate interest to use this information to improve the Game.
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 Not applicable to Website Version.	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 Not applicable to Website Version.	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.
Data analytics/profiling information (PSM): email	This function relates to ad attribution, and the UA team will use the email address collected to optimize the ad attribution effect of users. The collection of the email address only involves iOS users, and such data point will be processed and stored in the servers of Firebase.		It is in our legitimate interest to use this information to monitor the effectiveness of our advertisements and to provide a better gaming experience.
For PC Version only
Payment information (Midasbuy): purchased items and their costs, time, date and currency of the purchase, order ID, Open ID, player ID, country, game account balance and purchase history	We use this information to enable you to use the payment function in the PC Game.		It is in our legitimate interest to use this information to allow you to make payments in the Game, and to review your purchase history to restore purchased items.
Data analytics to analyse user acquisition statistics: user agent (e.g. safari or chrome or mozille or IE), PC UUID, timezone, resolution, IP address, language (and other common information for data reporting)	We use this information to analyse the user acquisition process and understand where the users who downloaded the Game originated from (Facebook, Google, Steam, Epic, etc.).		It is in our legitimate interest to use this information to understand the user acquisition process.
Game data from Unity 3D: PC UIID	We use this information to track logged-out user preferences between apps with the same signature key and for anti-fraud purposes.		It is in our legitimate interest to use this information to prevent cheating and understand user preferences.
Crash information (BUGLY): PC mac address, display card, GPU, CPU, physical memory, virtual memory, system API random-generated GUID, process name, application version, SDK version, SDK information, buried data reporting, resolution, dump file	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.
Security-related information (PC Version): in-Game clickstream data, recently opened program name, process information, device information (including hardware specifications and system information) and device identifiers, network information, disk information, program thread information, PC and Game window information, registry scan, suspicious file and driver information, account ID, game ID, MAC address, in-Game screenshots, and game scenes)	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.
Compliance information (For users under 18 located in the Republic of Korea): open ID, token, region, e-mail address of parents, weekend playing time limit, weekdays playing time limit, nickname, logon time (hours per month), payment activities in game	We use this information to comply with game-related regulations.		Legitimate interest to ensure compliance with applicable age-gating rules and other game-related regulations.
For Mobile Version and Website Version only
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.		If you live in the European Economic Area: We collect this information with your consent. If you do not live in the European Economic Area: 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.		If you live in the European Economic Area: We collect this information with your consent. If you do not live in the European Economic Area: 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.		If you live in the European Economic Area: We collect this information with your consent. If you do not live in the European Economic Area: 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 analyse user acquisition statistics (Google): hashed email address	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.
Security-related information (Mobile and Website Versions): 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.
For Website Version only
Cloud Gaming Login: Guest log-in information, Social media information, LEVEL INFINITE PASS Account log-in information.	We use this information to enable you to use the Service (via Website Version) in accordance with your request.		Necessary to perform our contract with you to provide the Game.
Cloud Gaming Resource Allocation Data: IP address, Open ID	We use this information to allocate cloud resources if you would like to use the Service.		Necessary to perform our contract with you to provide the Game.
	We use this information to carry out analytics on the performance and functioning of the Service in your city or region.		It is in our legitimate interest to ensure the functioning of and improvement of the Game.
User Active Information: Open ID and last login time	We use this information to ensure time limits or time extensions for playing the game are implemented and time limits are not circumvented.		It is in our legitimate interest ensure the integrity of the Service by ensuring time limits are not circumvented.
Cloud Gaming Duration Data: (via cookies) stay time on web browser session, token, token key	We use this information to determine your gaming duration (i.e., the amount of time you have spent on playing the game from a cloud server without downloading the game), and to calculate the remaining time you have (per day) to play the game from a cloud server without downloading the game (if applicable).		It is in our legitimate interest ensure the integrity of the Game by ensuring time limits are not circumvented.
Cloud gaming duration inheritance data: Open ID	We use this information to ensure time limits or time extensions for playing the game are implemented and time limits are not circumvented.		It is in our legitimate interest ensure the integrity of the Game by ensuring time limits are not circumvented. Necessary to perform our contract with you to provide time extensions for use of the Service from a cloud server without downloading the Game.
All other data collected for the Mobile Version also applies for the Website Version, except for payment information and system notification information. For all device related information, instead of processing the information of the device you are using to use the Game service, only the information of the virtual device assigned to you will be collected.	Please refer to the disclosures related to data collected by the Mobile Version.		Please refer to the disclosures related to data collected by the Mobile Version.

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, Japan, Korea, Malaysia and the People’s Republic of China.

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, including 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.
Email address (processed by LEVEL INFINITE PASS if you choose to log in via your LEVEL INFINITE PASS account and participate in Game events)	Stored for the duration of your use of the service and removed within 30 days if you request for deletion or if the service is shut down.
Account deletion information (Website)	Stored for a cool-down period of 30 days, after which it will be deleted immediately.
Level Infinite Account log-in information Guest log-in information Hashed Nickname 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 Payment information Payment information (Midasbuy) Data analytics to analyse user acquisition statistics Game data from Unity 3D (for PC Version) Compliance information Cloud Gaming Login Cloud Gaming Resource Allocation Data User Active Information Cloud Gaming Duration Data Cloud gaming duration inheritance data	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.
Security-related information (Mobile and Website Versions) Security-related information (PC Version)	Stored for up to 30 days, unless any violation (such as cheating behaviour) is found, in which case evidence of violation will be stored for the lifetime of your use of the Game and then deleted within 1 year thereafter.
Survey information	1 year. If you request for account deletion, data will be deleted within 30 days after your request.
Customer support information	For customer service log data: Stored until the Game is Terminated. If you request for account deletion, data will be deleted within 30 days after your request. For game data: Processed until your support ticket, query or review has been resolved or completed. For customer support information (other than customer service log data and game data): 2 years (unless you provide sensitive data, in which case such data will be deleted after your support ticket, query or review has been resolved or completed). If you request for deletion, data will be deleted within 30 days after your request.
User Report Information	2 years (unless you provide sensitive data, in which case such data will be deleted after your report or complaint has been resolved or completed). 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.
Data analytics to analyse user acquisition statistics (Google)	Stored for up to 140 days.
Data analytics/profiling information (PSM)	This data is not stored on our servers.
Firebase Instance ID	Stored for 24 months.
Compliance information (For users under 18 located in the Republic of Korea)	6 months after game server shutdown. If you request for deletion, data will be deleted within 30 days after your request.
Crash-related information	Stored for 90 days

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 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 or you can contact us at dpo@nikke-global.com.

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 correct personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account and correcting the personal information by contacting dpo@nikke-global.com.

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Game account and by contacting 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 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:

International Privacy & Data Protection Centre
30 Raffles Place #12-01
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.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

9. Changes

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

10. Language

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

INFORMATION FOR PARENTS

Before your child can use the 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 PC, mobile and webpage 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	4th Floor 80 Strand London WC2R 0RL	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.

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.

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.

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

Telephone: +603-22872388
Email: dpo@nikke-global.com

Mexico

Some of the purposes of processing specified in Section 3 (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.

Data Protection Team, responsible for the management and safety of your personal information
Contact: as set out in Section 8 (Contact)

Philippines

You are entitled to the following rights:

Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

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

collecting and processing your personal information as described in Section 3 (How We Process Your Personal Information);
sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
transferring or storing your personal information in destinations outside the Philippines as described in Section 3 (How We Store and Share Your Personal Information)

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”
Google https://business.safety.google/adsprocessorterms/	Hashed email address	User acquisition purposes and to monitor the effectiveness of our advertisements	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	Transferred via information and communications network at the time of service use	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	Transferred via information and communications network at the time of service use	All personal information collected	Storage of personal information	For the data retention period specified under “Data Retention”
Aceville Pte Ltd (cloudlegalnotices@tencent.com)	Singapore	Transferred via information and communications network at the time of service use	All personal information collected	Storage of personal information	For the data retention period specified under “Data Retention”
Midas (privacy@midasbuy.com)	United States	Transferred via information and communications network at the time of service use	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	Transferred via information and communications network at the time of service use	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	Transferred via information and communications network at the time of service use	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	Transferred via information and communications network at the time of service use	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	Transferred via information and communications network at the time of service use	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	Transferred via information and communications network at the time of service use	Customer support information	To provide you with customer support services	For the data retention period specified under “Data Retention”
Latis	South Korea	Transferred via information and communications network at the time of service use	Customer support information	To provide you with customer support services	For the data retention period specified under “Data Retention”
Transperfect	Japan	Transferred via information and communications network at the time of service use	Customer support information	To provide you with customer support services	For the data retention period specified under “Data Retention”
Microsoft Azure	United States	Transferred via information and communications network at the time of service use	Data Security information	Data security	For the data retention period specified under “Data Retention”
Google (https://business.safety.google/adsprocessorterms/)	United States unless otherwise described in the service provider’s privacy policy	Transferred via information and communications network at the time of service use	Hashed email address	To monitor the success of our advertising and marketing programs	For the data retention period specified under “Data Retention”

You may refuse the overseas transfer of your personal information by contacting our Data Protection Department. If you refuse the overseas transfer of your personal information, your personal information will not be transferred overseas. However, you may not be able to use our services for which overseas transfer of personal information is necessary.

Data Destruction

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

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

Act on the Consumer Protection in Electronic Commerce, Etc.

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

In an electronic commerce or a mail-order sale:

· Records regarding labelling and advertising (6 months)

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

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

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

Protection of Communications Secrets Act

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

· Log records, IP address (3 months)

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

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

Additional Use and Provision of Personal Information

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

whether the additional use/provision is related to the initial purpose of the collection;
whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;
whether the additional use/provision unfairly infringe on the interests of the data subject; and
whether the necessary security measures such as pseudonymization or encryption were taken.

Domestic Privacy Representative

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

Name: Kite Bird Korea Yuhan Hoesa
Address: 25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea
Telephone Number: +82-2-2185-0926
Email: specified in Section 7 (Contact)

Contact

Data Protection Department, responsible for the management and safety of your personal information
Telephone: +82-2-2185-0926
Email: dpo@nikke-global.com

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.

Email address (processed by LEVEL INFINITE PASS if you choose to log in via your LEVEL INFINITE PASS account and participate in Game events)

Account deletion information (Website): country/region, contact name, nickname, user id, email address, server, level

Purpose of Collection and Use

Mobile phone number, device information and IP address: To provide you with updates and notify you when the GODDESS OF VICTORY: NIKKE becomes available for download and to allow you to redeem your gift once GODDESS OF VICTORY: NIKKE is officially launched.

Email address (processed by LEVEL INFINITE PASS): If you participate in Game events, we use this information to distribute rewards.

Account deletion information (Website): to allow you to delete your account upon your request.

Period of Retention and Use

Mobile phone number, device information and IP address: 1 year after pre-registration is completed. If you request for deletion, data will be deleted within 7 days after your request.

Email address (processed by LEVEL INFINITE PASS): Stored for the duration of your use of the Service and removed within 30 days if you request for deletion or if the Service is shut down.

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

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 Game

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 Game

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 [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, 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. Do you agree to our collection and use of the following personal information?

Items to be Collected

· LEVEL INFINITE PASS Account log-in information (if you choose to log-in via LEVEL INFINITE PASS Account): UID, token, email, username

· 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 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

· Hashed Nickname

· Email delivery information: Email address

· Customer support information: Game user account and contact information (including your user nickname and icon, open ID, APPID, country selected by you during registration, login channel and channel ID, registered username, social account, mobile phone, registration time, level, email address and email verification code); Login status verification information; Device information; Game data: Game character information (including your role name and role ID, game data and records, frequency of playtime, game history), and in-game data (including items, purchase and top-up information, penalties, activities, game match data, in-game friends); User report information (including information of reporting user and reported user, report descriptions, game match data, punishment, in-game chat information, report processing results and reasons);] [Device information such as device ID and IP address (only applicable for guest users that have lost their account); Customer service log data (including Open ID, ticket date, type of request); Any other details/information (including any documents/media) that you choose to provide to us as part of your ticket, query or review, and your contact information.

· 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; For PC: PC mac address, display card, GPU, CPU, physical memory, virtual memory, system API random-generated GUID, process name, application version, SDK version, SDK information, buried data reporting, resolution, dump file

· 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 (Mobile and Website Versions): 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)

· Security-related information (PC Version): in-Game clickstream data, recently opened program name, process information, device information (including hardware specifications and system information) and device identifiers, network information, disk information, program thread information, PC and Game window information, registry scan, suspicious file and driver information, account ID, game ID, MAC address, in-Game screenshots, and game scenes)

· Data analytics/profiling information (Appsflyer) [Mobile Version and Website Version only]: 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) [Mobile Version and Website Version only]: 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.

· Data analytics to analyse user acquisition statistics (Google) [Mobile Version and Website Version only]: Hashed email address

· Data analytics/profiling information (PSM): email:

· Payment information (Midasbuy) [PC Version only]: purchased items and their costs, time, date and currency of the purchase, order ID, Open ID, player ID, country, game account balance and purchase history

· Data analytics to analyse user acquisition statistics [PC Version only]: user agent (e.g. safari or chrome or mozille or IE), PC UUID, timezone, resolution, IP address, language (and other common information for data reporting)

· Game data from Unity 3D [PC Version only]: PC UIID

· Compliance information (For users under 18): open ID, token, region, e-mail address of parents, weekend playing time limit, weekdays playing time limit, nickname, logon time (hours per month), payment activities in game

· Crash- related information - For mobile version: user IDs, IDFV, device identifiers, device information, storage, network status, logs, startup time, IP country location, exception information; For PC version: user IDs, PC mac address, operating system name, graphic card name, machine memory, resolution, startup time, device identifiers, IP country location, exception information, CPU, GPU and system information, storage, network status, log

· Cloud Gaming Login (Website Version only) – Guest log-in information, Social media information, LEVEL INFINITE PASS Account log-in information.

· Cloud Gaming Resource Allocation Data: IP address, Open ID

· User Active Information (Website Version only): Open ID and last login time

· Cloud Gaming Duration Data (Website Version only): (via cookies) stay time on web browser session, token, token key

· Cloud gaming duration inheritance data (Website Version only): Open ID

· For Website Version - All other data collected for the Mobile Version also applies for the Website Version, except for Payment information and System notification information. For all device related information, instead of processing the information of the device you are using to use the Game service, only the information of the virtual device assigned to you will be collected.

Purpose of Collection and Use

· LEVEL INFINITE PASS Account log-in information (if you choose to log-in via LEVEL INFINITE PASS Account): to link your game account to your Level Infinite Account in accordance with your request.

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

· Hashed Nickname: to publish the hashed version of your nickname on our Website and in the Game.

· 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/profiling information (PSM): This function relates to ad attribution, and the UA team will use the email address collected to optimize the ad attribution effect of users. The collection of the email address only involves iOS users, and such data point will be processed and stored in the servers of Firebase.

· 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 (Mobile and Website Versions): to ensure the security and safety of the services of the Game (such as through anti-cheat functions).

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

· Data analytics/profiling information (Appsflyer) [Mobile Version and Website Version only]: for ad attribution.

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

· Payment information (Midasbuy) [PC Version only]: We use this information to enable you to use the payment function in the PC Game.

· Data analytics to analyse user acquisition statistics [PC Version only]: We use this information to analyse the user acquisition process and understand where the users who downloaded the Game originated from (Facebook, Google, Steam, Epic, etc.).

· Game data from Unity 3D [PC Version only]: We use this information to track logged-out user preferences between apps with the same signature key and for anti-fraud purposes.

· Data analytics to analyse user acquisition statistics (Google) [Mobile Version and Website Version only]: We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements.

· Compliance information (For users under 18): We use this information to comply with game-related regulations.

· Crash- related information: We use this information to locate and resolve crash issues.

· Cloud Gaming Login (Website Version only): We use this information to enable you to use the Service (via Website Version) in accordance with your request.

· Cloud Gaming Resource Allocation Data (Website Version only): We use this information to allocate cloud resources if you would like to use the Service, and we use this information to carry out analytics on the performance and functioning of the Service in your city or region.

· User Active Information (Website Version only): We use this information to ensure time limits or time extensions for playing the game are implemented and time limits are not circumvented.

· Cloud Gaming Duration Data (Website Version only): We use this information to determine your gaming duration (i.e., the amount of time you have spent on playing the game from a cloud server without downloading the game), and to calculate the remaining time you have (per day) to play the game from a cloud server without downloading the game (if applicable).

· Cloud gaming duration inheritance data (Website Version only): We use this information to ensure time limits or time extensions for playing the game are implemented and time limits are not circumvented.

Period of Retention and Use

· LEVEL INFINITE PASS Account log-in information, Guest log-in information, Hashed Nickname, 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, Payment information; Compliance information, Payment information (Midasbuy) [PC Version only], Data analytics to analyse user acquisition statistics [PC Version only], Game data from Unity 3D [PC Version only] : 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.

· Security-related information (PC Version), Security-related information (Mobile and Website Versions): Stored for up to 30 days, unless any violation (such as cheating behaviour) is found, in which case evidence of violation will be stored for the lifetime of your use of the Game and then deleted within 1 year thereafter.

· Customer support information: For customer service log data: Stored until the Game is Terminated. If you request for account deletion, data will be deleted within 30 days after your request. For game data: Processed until your support ticket, query or review has been resolved or completed. For customer support information (other than customer service log data and game data): 2 years (unless you provide sensitive data, in which case such data will be deleted after your support ticket, query or review has been resolved or completed). If you request for deletion, data will be deleted within 30 days after your request.

· Data analytics/profiling information (AppsFlyer) [Mobile Version and Website Version only]; Data analytics/profiling information (Firebase): Stored for up to 14 months.

· Data analytics/profiling information (Facebook) [Mobile Version and Website Version only]: 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 [Mobile Version and Website Version only]: Stored for 24 months.

· Data analytics/profiling information (PSM): Not stored on our servers.

· Data analytics to analyse user acquisition statistics (Google) [Mobile Version and Website Version only]: Stored for up to 140 days.

· Compliance information (For users under 18): 6 months after game server shutdown. If you request for deletion, data will be deleted within 30 days after your request.

· Crash-related information – Stored for 90 days.

· Cloud Gaming Login, Cloud Gaming Resource Allocation Data, User Active Information, Cloud Gaming Duration Data, Cloud gaming duration inheritance data (Website Version only): 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.

[Optional] Notifications / Electronic transmissions / Surveys

Optional Consents

Certain features of the GODDESS OF VICTORY: NIKKE 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 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 GODDESS OF VICTORY: NIKKE.

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

Name: Karanovic & Partners o.a.d. Beograd
Address: Resavska 23, Belgrade, 11000, Serbia
Telephone Number: +381 11 3094 200

E-mail: local.representative@karanovicpartners.com

Singapore

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

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

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

South Africa

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

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 or regions other than Ukraine, to the extent and for the purposes provided in this Privacy Policy.

United States

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information, including sensitive personal information (denoted by *), from or about you or your device:

Identifiers, such as your name 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.
Personal information categories listed in the California Customer Records statute, including information covered by other categories such as your address and phone number. This information is collected directly from you.
Characteristics of protected classifications under California or federal law such as national origin, gender, or age. This information is collected directly from you in the context of being our consumer or, if you choose to set up your profile using a social media account, your gender may be provided by your social media account provider.
Internet or other electronic network activity information, such as your information regarding your use of the Game, 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.
Commercial information about any transactions within the Game such as what products were purchased and how much they cost. This information is collected directly from you and your device and the Google Play or Apple iOS store.
Geolocation information such as your region location when you set up your profile and choose to provide this information for the Game. This information is collected directly from you.
Visual information such as your social media profile picture. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.
Professional or employment-related information such as your profession if you choose to provide it in a survey. This information is collected directly from you.
Account log-in information, including the username and password used to access your Game account.*
Contents of your chat messages sent on Game*. This information is collected from your device, is only stored on your device, and is not retained by our servers.

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

To provide you with the Website and the Game, maintain your account, provide customer service, process payments, and deliver text messages.
To process surveys.
To improve our services, including the functionality of the Website and the Game.
For security and verification purposes, including to prevent and detect fraudulent activity.
To address and remediate technical issues and bugs.

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

We disclose each of the categories of personal information that we collect as described in Section 4 (How We Store and Share Your Personal Information).

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.

Retention of Your Personal Information

The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.

California Users Under 18

Any California residents under the age of eighteen (18) who have registered to use the Game and Website and who have posted content or information on the Game and Website can request that such information be removed from the Game and Website by contacting us as specified in Section 8 (Contact). Such request must state that they personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the resident cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post, and archived copies of it may be stored by search engines and other parties that we do not control.

Rights under US State Laws:

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:

the categories of personal information about you that we collected;
the categories of sources from which the personal information was collected;
the business or commercial purposes 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 to Delete. Request we delete personal information we collected about you;
Request to Correct. Request we correct inaccurate personal information that we maintain about you; and
Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 8 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.

Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

Questions

If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 8 (Contact).