Your Privacy Matters to Us
The term “personal data(“personal information”, “information”)” may include your name, device ID, e-mail address, date of birth, gender, your application preferences, for instance. But anonymous data, which we cannot relate to you, does not qualify as “personal data”.
1. HOW WE COLLECT INFORMATION
1.1. Information we collect directly
We collect personal data and other information you provide directly. It is entirely your choice to provide the data we requested. However, if you provide your personal data for a specific purpose, such as creating a new account, only certain services are available for that purpose.
When you create an account, you can be asked to provide personal data that includes your email address, date of birth, member ID and gender information. In addition, the personal data collected is not limited to this.
We may collect your personal data when you use our services, such as application forums, chats, etc., or when you provide feedback about our services. This data includes.
● Personal data sent through the "application chat" feature in the application;
● Personal data that you post or comment in any of the application-related forums, websites owned or operated by Artrict, on the pages of social network groups operated by Artrict;
● Information you provide when you request information or support from us or purchase a product or service from us, including information necessary to process your orders with the relevant payment merchant, which may include the amount of any transaction, but will not include your financial information, which will only be submitted directly to the payment merchant under secure protocols; and
● Information excepting the account data you provide to us when participating in tournaments, contests, at online events, or responding to surveys, e.g. your phone number or address;
1.2. Information we collect indirectly
We indirectly collect personal data and other information through interactions when you use our applications, websites, and other services.
This information may include, but is not limited to, device information(device ID, OS, OS version, ADID, UDID, language and country settings), connection record(IP address, connection IP, login time and dates), PC specification, cookie, anonymized browser, data collected through automated electronic interactions, application usage data, statistical and aggregated information.
Statistical or aggregated information does not identify a specific person directly, but it could be derived from both personal data and information. We can aggregate personal data to calculate the percentage of users who use our applications in a country, for example. If other information is combined with personal data, we will identify and process the combined information as personal data.
1.2.1. Application-related information
We may need to collect, store and use various information about your activity in our applications in order to provide you with efficient services.
This, application-related information, includes your in-application identifier, which for most of our applications is known as account ID or email address, as well as what is usually referred to as application statistics.
By application statistics, we mean information about your preferences or progress in the applications, participation and performance in clans, and frequency of playing.
1.2.2. Device information
While you are installing our applications and using our application services, we collect, store and treat information about the device you are using, including what type of device it is, what kind of hardware and operating system you are using, unique device identifiers, android ID, IP address, connection IP, PC specification and crash data, in order to fix crashes and other technical issues that may arise. Whether we collect some or all of this information often depends on what type of device you are using.
1.2.3. Information required for fraud and violations detection
We may also collect certain data such as IP address, username that could be required for investigation and prevention of cheating in the application and EULA violations. This data, being used only for the purposes of investigation and prevention of frauds and cheating in the application will be deleted 1 year after its collection, unless the data can be used to prove that cheating has occurred. If the data can be used to prove that cheating or another fraud or EULA violation has occurred, we will store the data longer than 1 year for the establishment, exercise or defense of legal claims during the applicable period of filing a complaint.
The specific data stored for this purpose may not be disclosed to both you and any third parties, because the disclosure will compromise the mechanism through which we detect, investigate and prevent frauds and cheating in the application, as well as other EULA violations.
1.2.4. Information from publicly available online resources
We may use the information made publicly available in Facebook or YouTube to find out your opinion about our applications or services.
This, collecting such data, could be carried by Artrict independently, or can be carried by our marketing partners making analysis of public sentiments on various issues.
1.2.5. Information from our partners
In some cases, we could receive your personal data as a data processor, which means that your personal data is controlled by our partners and we only use it in accordance with their instructions and applicable laws. We will use this data to fulfill obligations under EULA, improve services, or comply with legal obligations.
Payment partners. We may receive a part of your credit card number, information about your credit card issuer from our payment partners when you purchase online and mobile application items, virtual cashes with your credit card.
Platforms. We also receive and use your information through other platforms such as Apple Store, Google Play, PlayStation4, Xbox, Steam, etc. so that you can play our applications through these platforms.
Social networks. We have registered certain applications-related group accounts and pages at Kakao, Facebook, Naver, Line and other social networks to do better communication with our application players. So, we may get information relating to your profiles on social networking sites. e.g., character name, and date of birth.
2. HOW WE USE YOUR INFORMATION
We need to process your personal data to perform the contract with you. We will use your personal data, unless otherwise prohibited by law, for the following purposes:
● to allow your installation of our applications, provide the services, verify and confirm your payments;
● to check your account or communicate with you about transactions and send you information about features on our websites or changes to our policies;
● to provide application update information, application patches and fixes and other similar communications; and
● to send you gifts and awards, to which you may be entitled as a result of winning an online or offline competition, etc.
2.1. Communication purposes
We will use your personal data for our legitimate interests and to advertise our products and services in accordance with this policy.
Once you create an account we may use your email address, nickname, IP address, connection IP, country settings in order to send you personalized marketing emails, messages, targeted in-application offers about our applications.
2.2. In-application offers
We will send you in-application offers that are useful to you by using application-related information we collected.
2.3. Services improvement purposes
We will analyze your personal data to find out how to improve our application services to make them more suitable and interesting for you and other players. Also we may ask you to respond to our services-related questionnaires, and you always have the choice about whether to respond to them and which information you will provide.
2.4. Fraud and EULA violations detection
We may use your personal data required for investigation and prevention of cheating in our application and violations of EULA or policies for the purposes of investigation and prevention.
3. HOW WE SHARE YOUR INFORMATION
We may share your personal data for the performance of the contract with you, the compliance with a legal obligation or our legitimate interests with the following categories of third parties.
3.1. Payment partners
We may share your date of birth, email address, IP address or information about in-application purchases requested by you on Artrict's websites, and other information you provide to us for the purpose of fulfilling your purchase or withdrawal requests.
3.2. Data storage partners
We may store your personal data using third-party data storage services such as Google Cloud Platform(GCP), Amazon Web Services(AWS).
3.3. Research partners
We may provide access to some of your data, such as application statistics, to provide marketing-related and other research. We also may share anonymous data with our partners unless your personal data is necessary for the requested services or research.
3.4. Customer service partners
We may share your personal data with third parties to provide you with customer services and support effectively. Such partners may get access to your personal data only for the purposes mentioned above. For more information about these partners, please contact us.
3.5. Publicly available information
Our websites may have bulletin boards, forums where users can exchange ideas and communicate with each other. When you post a message to a board, forum, please be aware that your message and the information about you are being made publicly available on-line. Therefore, please do not include any data in your nickname that will personally identify you.
3.6. Sharing anonymous information
We may share anonymous data, which does not directly or indirectly disclose your identity, and aggregated information such as application statistics, categories of users which does not identify and that cannot be used to identify any individual user with our advertising partners. We may also allow our advertisers to collect and aggregate anonymous data about our services and they may share the information with us. They may also collect this information through the use of tracking technologies like cookies and web beacons. This enables to develop and deliver targeted advertising in our services and on the websites of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you.
4. HOW LONG WE KEEP YOUR INFORMATION
Generally, we will delete your personal data after you request your account deletion and the grace period of 30 calendar days, during which we can restore your account, expires. However, considering the complexity and number of requests, it can be extended for another one month sometimes.
When we no longer need to keep your personal data, we will delete it from our data processing server.
We will also delete your personal data immediately after a request to unsubscribe for the purposes of resolving unwanted customer complaints or disputes. But sometimes it may take longer than 15 days depending on the individual operational policy of the application you play.
5. COOKIES AND SIMILAR TECHNOLOGIES
Cookies. Cookies are essentially small data files placed on your computer, mobile phone, tablet or other devices that allow us to record certain pieces of information whenever you visit our websites or interact with our services. Most browsers allow you to block and delete cookies.
You can refuse all cookies, confirm each time a cookie is saved or permit all cookies by going to [Tools]>[Internet option]>[Security]>[Custom setting], or by using the settings or options function on mobile devices. However if you do that, some of our services may not work properly.
Web beacons. Web beacon is a piece of code embedded on our services that collects information about your engagement on that web page. The use of a pixel allows us to record, for example, that you have visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Mobile device identifiers. We may share the advertising identifier associated with your mobile device or tablet. We use the Apple IDFA only as permitted by Apple, and we use the Google Advertising ID only as permitted by Google. An advertising identifier is assigned, and ad tracking is turned on, by default on your mobile device. You may limit the use of or reset your advertising device ID using the privacy settings on your mobile device. In some cases, you may need to reset the operating system to reset the advertising device ID
Google analytics. We may also use Google Analytics to collect information regarding your behaviors to get demographics of our services. For more information about Google please visit http://www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the services by going to http://tools.google.com/dlpage/gaoptout.
Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what website and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
The use of these technologies falls into the following categories;
Related to performance. We may use technologies to collect information about how our services are performing. We may use the information to compile reports and to help make improvements to our services.
Related to functionality. We may use technologies that allow us to offer you enhanced functionality when accessing or using our services. This may include identifying you when you sign into our services or keeping track of your specified preferences, interests, or past items viewed;
Related to research. We may use technologies to collect information about how you use our services, including the total number of users that use our services and the types of devices they use; and
Related to advertising. We may use technologies to deliver content, customize the advertising relevant to your interests in our services or websites.
We fully know that we have a special obligation to protect children’s information. Our applications are intended for persons aged over 16 in EU, or aged over 13 in U.S., otherwise defined in your country of residence or older than such applicable age.
We make reasonable efforts to verify that consent is given by your parent or legal guardian and if we collected personal data from you without their consent, we will delete it immediately.
California minors. We do not collect personal data of minors under 16 who are residents of California without their affirmative authorization, or the affirmative authorization of their parent or legal guardian for minors under 13.
8. INTERNATIONAL DATA TRANSFERS
9. YOUR RIGHT
9.1. General rights
Right of access. You may have the right to confirm that we are processing and gain access to your personal data. Should you have any questions regarding the processing, or would you like to have more insight in your personal data that we process, you are always welcome to contact us, and we will provide you with further information.
Right to rectification. You may have the right to request that we correct data that we have inaccurately stored. You may also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to be forgotten. You may have the right to request from us to permanently delete your personal data. You can make such a request if you, for example, believe that the personal data are no longer necessary in relation to the purpose for which the personal data were collected or otherwise processed.
Right to restrict the processing activities. You may have the right to restrict our processing activities. If you choose to restrict our processing activities as relates to providing our services, you might not be able to use them.
Right to data portability. You may have the right to request from us that we send your personal data to you in a structured, commonly used and machine-readable format, and transmit your personal data to another controller.
Right to object. You may have the right to object to our processing of your personal data. If you choose to object to our processing activities, you might not be able to use all of our services.
Right to lodge a complaint with a supervisory authority. If you are unsatisfied with the way we treat your personal data, you may reach out to us at all times to solve the issue. Also you always have the right to lodge a complaint with a supervisory authority.
Right to withdraw consent. Where our processing of your personal data is based on your consent, you may have the right to withdraw such consent at any time. The withdrawal of your consent will not affect the lawfulness of the processing based on consent before its withdrawal.
If you would like to exercise any of the rights listed above, please contact us at [email protected]
9.2. Your choices
10. CHANGES TO THIS POLICY
11. CONTACT US
Title : Data Protection Officer
Email : [email protected]
Name : Hyoowan, Jun
Address : 06568 Bangbae Diosuperium1 B-Dong 2005, 3-4, Seocho-daero, Seocho-gu, Seoul, Republic of Korea
12. ADDITIONAL DISCLOSURES