Welcome to Arena Breakout: Infinite!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the Services 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 Services. 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 Services. By using the Services 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 Services is Proxima Beta Pte. Limited (“we”, “us”, “our”, or “Proxima Beta”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us to reach out data protection officer. 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 Services for any purpose. 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. 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
Algeria	19
Argentina	13
Australia	18
Bangladesh	18
Brazil	18
Cambodia	18
Canada	13
Colombia	18
Egypt	18
European Economic Area	16
Hong Kong	18
Indonesia	21
Japan	18
Kazakhstan	18
Kuwait	21
Macau	18
Malaysia	18
Mexico	18
Morocco	18
Myanmar	18
New Zealand	16
Nigeria	13
Philippines	18
Qatar	18
Saudi Arabia	18
Serbia	15
Singapore	13
South Africa	18
South Korea	19
Sri Lanka	18
Switzerland	14
Thailand	20
Tunisia	18
Türkiye	18
United Arab Emirates	21
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.

It also identifies the legal basis under which we process your data under applicable data protection laws.

Personal Information	Use	Legal Basis (where applicable)
*Website only*
Information you provide to us (either directly or through a third party)
Age information (for users in certain jurisdictions): · Date of birth - we only process this momentarily to confirm your age status (adult / minor) and do not store this on our servers. · Age status – whether you are a minor / adult	We use this information to verify your age if you are a user in certain regions.	Date of birth: N/A Age status: To comply with our legal obligations under applicable laws.
IP address and country For IP address, we only process this momentarily and do not store this on our servers.	We use this information to: · suggest your country / region when you input your location during account registration; · ensure the correct version of the Website is shown to you; and · verify whether the Game is available in your country / region.	It is in our legitimate interests to ensure the correct version of the Website is shown to users depending on their location.
Email address	· We use this information to send you news / newsletters, promotions and offers about the Game	We use this information with your consent.
Pre-registration event data: · Streamer registration information: streaming platform (Twitch or YouTube), streamer’s name, link, UID (optional), teammates’ UID (optional), Discord ID and email address. · Streamer cash prize information: name, email address, payment information (bank account number, bank swift number, bank billing address, streamer · Leaderboard information: streamer name, ranking. · Gamers’ performance information: combat performance information including combat ID, player / team user ID and nicknames, kill count, number of gold tags collected.	We use this information to enable you to pre-register and participate in the official online event of the Game.	We use this information with your consent.
Cookies information (collected via Google Analytics) including the following: · your browsing behaviour while using the website, including time on the website (the total time spent on the website; the time spent on each page and in what order the pages were visited, what internal links were clicked (based on the URL of the next pageview) · user agent string · initial page inspection · geographic location · operating system information · browser information · device information including screen size · referring site · IP address	We use this information to maintain and monitor the performance of the Website and to improve the Website and the services it offers to our visitors. Please refer to our Cookies Policy here for more details.	It is in our legitimate interest to use this information to monitor the performance of, and to improve, our services and the Website.
*Game only*
Information you provide to us (either directly or through a third party)
Game survey data (aggregated data): · Any information requested as part of the survey (e.g. email, country, gameplay frequency, favourite game categories, language preference etc.) and any other content you choose to provide as part of the survey response. · Device data: IP address, browser, browser version, device settings and operating system version. The survey will indicate which data fields are mandatory / optional to provide. If you choose to participate in an in-game survey, we will only receive an aggregated report of the above data.	We use this information to allow you to complete the survey (if you wish to participate) in-app (using IMUR).	We use this information with your consent.
Survey information (via IMUR): Personal information provided by you in responses to a survey which might include your email, phone number, steam friend code, country or region of residency, gaming habits and preferences (including recently played games, gameplay frequency, favourite game categories and experience, language preference, evaluation and comments towards the Service), and other survey responses content that you may choose to provide.	We use the survey information to allow you to participate in surveys about the Service to improve the Service, to facilitate the connect with you and to distribute rewards.	We use this information with your consent.
Data Subject Request Ticket Information: Information of the data subject: Your country/region, alias or name, email address, user ID, information related to your Game account (such as in- Game screenshot(s), account registration date, login method and/or connected social media accounts, cash/token/points balance information), any other information necessary for identity verification or to respond to your request. Information of requestor (if submitting on behalf of data subject): Requestor's name, email address, requestor's relationship with user, proof of identity, proof of user's identity, requestor's authority, any other information necessary for identity verification or to respond to your request. Communications with you relating to your data subject request ticket and any other information provided by you.	When you submit a data subject request ticket (or someone submits a request on your behalf), we collect this information to: verify your identity (and, if applicable, the requestor’s identity if different from the data subject); and evaluate, respond to, process, and communicate with you regarding your data subject request.	Necessary to comply with a legal obligation.
Account Security Information： Graphics Card Model, CPU Model, Display Screen Model, and Mouse Model and any information you submit for setting up a secondary password. Device information, such as Mobile brand, Mobile model, Country code, Device language (zh-Hans-CN), Screen resolution and OS version	We use the account security questions information allow you to set up a secondary password for your account to enhance account security and to verify the accuracy of your answers. We may also use this information to maintain transaction security.	We use this information with your consent. It is in our legitimate interest to use this information to ensure security of the service.
Information generated as part of the Game
Real time voice data (if available in your jurisdiction): · Identity information: OpenID · Device information: device name, device model, device brand, output and input IP address, UUID, device manufacturer, system time, microphone signal · Other: SDK version, IP address, network type and voice file	We use this information to: · facilitate your real time voice chat with other users; and	Necessary to perform our contract with you to provide the Game.
	· for quality and service availability analysis.	It is in our legitimate interest to improve the Game.
Microphone data: microphone signal and voice file	We use this information to enable you to report and for us to review audio content that violates our user agreement.	Necessary to perform our contract with you to provide the Game.
Chat data (if available in your jurisdiction): OpenID, text chat Chat data is processed to enable public chats and private chats within the Game. Please note that we do not store public chat data on our server.	We facilitate the posting of your text chat communications with other users.	Necessary to perform our contract with you to provide the Game.
Data analytics data (report key statistics): Common information for data reporting including event name, stage number, stage name, stage status, stage error code, game ID, stage time.	We use this information to report key statistics from the processes of log-in and Game update.	It's in our legitimate interest to use this information to monitor the success and smooth operation of the Game.
Anti-cheating data: · Account information: account ID, log data, IP address, users’ time zone and game ID · Device information: MAC address (encrypted) and OS version · In-game screenshots of your gameplay, which may contain nicknames and chats of you and your teammates (this information will be obfuscated and only collected if your account is identified as having suspicious activity, e.g. multiple user reports about your account)	We use this information for detect anti-cheating behaviour, implement countermeasures and profanity filters.	It is in our legitimate interest to ensure the security of our Game, to provide a fair environment for players, and to improve the Game.
Analytics and profiling data (collected via and shared with Appsflyer, a third party SDK): · 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, openID, · Engagement information: ad clicks/impressions, 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, URL from the referring website, downloads and installations, other interactions, events and actions customers choose to measure and analyse.	We use this information to carry out data analytics, app performance analytics and profiling for ad attribution purposes to understand how our users interact with advertisements.	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.
Crash-related information: operating system name, graphics card name, CPU type, machine memory, resolution, process name, startup time, and IP address, network status, IDFV, log data, crash stack information and crash logs.	We use this information to locate and resolve crash issues and for debugging.	It is in our legitimate interest to improve the Game’s functionality.
Game performance analysis data: · Identity information: OpenID · Device information: phone memory, GPU information, CPU model, CPU usage rate, device brand, network traffic, device system version, screen resolution, ROM, RAM, device manufacturer, CPU architecture, remaining memory, device model, system time, UUID, system startup time · Other: Frames per second, SDK version, network type, application version, application package name	We use this information to report on gameplay performance, statistics and analysis.	It is in our legitimate interest to measure and analyse the performance of the Game.
Device class analysis data: CPU model, GPU information, phone memory, device brand, RAM, ROM, device model, device name.	We use this information to analyze game performance based on device hardware information.	It is in our legitimate interest to ensure the functioning of, and improve, the Game.
Buried data analysis: CPU model, GPU information, device brand, input and output IP address, device manufacturer, ROM, RAM, CPU architecture, remaining memory, device model, device name	We use this information to carry out analytics on the performance and functioning of the Game based on device hardware from different manufacturers.	It is in our legitimate interest to ensure the functioning of, and improve, the Game.
Statistic and analysis data: OpenID, device brand, model, name and manufacturer.	We use this information to report on statistics related to the Game’s frequency of experiencing a down system.	It is in our legitimate interest to ensure the proper functioning of the Game.
Network performance data: OpenID, device name and model.	We use this information to monitor network quality and performance.	It is in our legitimate interest to ensure the proper functioning of the Game.
Device performance data: Phone memory, device brand, device system version, device manufacturer, ROM, screen resolution, RAM, system time, device model, device ID, device name, CPU model, CPU architecture, app list, SDK version, IP address, mobile network code, network type, application package name, application version.	We use this information to monitor device performance during the Game and improve your experience when playing the Game.	It is in our legitimate interest to measure and analyse the performance of the Game.
Game data: OpenID, IP address (only kept in aggregated format for server improvement), device model, game play statistics (e.g. level, nickname)	We use this information to store your game account information.	Necessary to perform our contract with you to provide the Game.
Log data: OpenID, nickname and property, player key operations in Game, player game level, task list, battle records, team information.	We use this information for debugging purposes.	It is in our legitimate interest to ensure the security and functionality of the Game, to provide a fair and secure environment for players and to improve the Game.
Optimisation data: OpenID and nickname	We use this information to store user account information and to optimize your experience in the Game.	Necessary to perform our contract with you to provide the Game.
Optimisation data: OpenID and nickname	We also use this information to perform game analysis, such as analysing players’ game style and preferences.	It is in our legitimate interests to measure and analyse the performance of the Game.
Transaction data: Purchased items and their costs, time, date and currency of the purchase, order ID, Open ID, country, game account balance and purchase history	We use this information to enable you to view your purchase history and to restore purchased items.	Necessary to perform our contract with you to provide the Game.
Clipboard data: OpenID and clipboard information We do not store this data on our servers.	We use this information to enable you to use the clipboard function and copy and paste text / content.	Necessary to perform our contract with you to provide the Game.
H5 data: Country and region, your browser version information, openID, and IP address.	We use this information to measure the performance of H5 activities based on your engagement with such activities within the Game.	It is in our legitimate interests to measure and analyse the performance of the Game.
Email notification data: Email address, open ID, user’s region	We use this information: · to provide you with service-related notifications (these cannot be opted out of); and	Necessary to perform our contract with you to provide the Game.
	· to provide you with notifications about various in-Game activities and marketing activities (e.g. if you’ve subscribed to specific aspects of the Game, such as weapons, skins etc.)	We use this information with your consent.
Events and quality analysis data: Email address, open ID	We use this information: · to undertake statistical analysis and quality monitoring; and	It is in our legitimate interest to use this information to optimize our game performance and improve our in-Game events.
	· to enable you to register and participate in in-Game events.	We use this information with your consent.
Game behaviour data: Information on whether you have engaged in malicious activities when playing the Game, such as maliciously harming teammates, maliciously grabbing resources, teaming up with cheating users and player report data.	We use this information to generate a merit score for users based on their in-game behaviour, such as whether they are frequently reported for offensive language, insulting teammates, or other misconduct, and identify misconduct.	It is in our legitimate interest to identify users engaged in misconduct and promote the safety and integrity of the Game.
For Events We will provide you with additional notice if the information collected for a specific event exceeds the scope below.
Information you provide to us (either directly or through a third party)
Identifying Information (e.g. name, address and post code (if applicable), contact information (email address, telephone number), date of birth, country of residence, game ID and character information, UUID, username, social media IDs and information, event-specific identifiers, government-issued document identifiers, and similar identifiers)	We use this information for one or more of the following purposes: · to facilitate access to the Event; · we use identifying information like date of birth, country of residence, and government-issued document identifiers for: (i) offline tournaments registration (e.g. relating to hotel bookings); (ii) delivery of physical prizes or cash prizes; and · to provide an engaging experience.	Necessary to perform our contract with you in connection with the Event. It is in our legitimate interest to provide an engaging gaming experience for our users.
Financial Information (e.g. payment information, bank account details, and similar financial data)	We use this information for one or more of the following purposes: · to facilitate access to the Event, maintain records; · to send and administer Event-related physical and cash prizes; and · to optimize game performance, server management, ensure smooth gaming experience.	Necessary to perform our contract with you in connection with the Event. It is in our legitimate interest to use this information to optimize our game performance and experience.
Survey Information: Any information requested as part of the survey (e.g. email, country or region of residence, gaming habits and preferences, gameplay frequency, favourite game categories, language preference, and any other responses you choose to provide as part of the survey response)	We use this information: · to allow you to participate in surveys about an Event, to improve the Service, and for registration purposes. · to send you news, events and promotions relating to the Event.	We collect this information with your consent.
Information generated as part of Events
Device and Network Information (e.g. device ID, operating system, IP address, device specifications, and similar technical data)	To facilitate access to the Event, maintain records, optimize game performance, server management, ensure smooth gaming experience.	Necessary to perform our contract with you in connection with the Event.
Gameplay and Interaction Data (e.g. in-game performance data, items and prices, game profile, usernames or nicknames, behavioural data, communication data, feedback or survey responses, likes and dislikes, interests and habits, lifestyle information, preferences, leaderboard and ranking information, streamer-related information, and similar gameplay and interaction data)	We use this information for one or more of the following purposes: · to track progress, maintain records, and provide Event-related rewards; · to identify and rank users in the game or on leaderboards, improve game balance and design, facilitate in-game chat or communication, collect feedback, improve game design, Event-related rewards; and · to provide an engaging experience.	Necessary to perform our contract with you in connection with the Event. It is in our legitimate interest to provide an engaging gaming experience for our users.
Media and Additional Data (e.g. pictures, videos, other personal information or gameplay data related to cheating prevention, health-related information, video footage of gameplay, recorded images, and similar media and additional data)	We use this information for one or more of the following purposes: · to allow social and traditional media promotion; · to prevent cheating, and protect other players; and · to provide an engaging experience	It is in our legitimate interest to promote the Event, ensure a safe gaming environment, and to provide an engaging experience.

4. How We Store and Share Your Personal Information

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 Services in Singapore. We also have support, engineering and other teams who may support the Services, including from Singapore and the PRC.

For EEA and UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses 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 Services, including Tencent Cloud, a provider of cloud services that stores information identified in this policy in Singapore, third party SDKs (e.g. from Appsflyer) for the purpose of monitoring the success of our marketing and advertising programs and profiling, monitoring and analysing views, clicks and engagement with the advertisements displayed in the Game, which process the relevant data analytics, profiling and user acquisition data identified in the policy in the United States, Belgium and Ireland, and providers that carry out surveys. We use Google Analytics to collect cookies information. You may find more information on how Google Analytics processes and safeguards data here. 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 Services (i.e., for the purpose(s) described above).

· Third-party partners that we collaborate with in providing the Service, including payment processors that facilitate in-app purchases, social media platforms if you participate in our activities through the platforms or if you otherwise choose to share certain information to social media platforms linked through our Service (such as when you choose to open or be redirected from our Website to a social media platform to post or share content relating to the Service), and analytics and marketing companies, etc. These companies will process your personal information and govern your use of their services and products in accordance with their terms and privacy policies.

· Companies within our corporate group who process your personal information solely for the purpose of providing the Services 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:

enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
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 Services 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
Country Age status	Stored for the lifetime of your LIP Account or until account deletion in accordance with your request, upon which it will be deleted within 30 days. Where you do not request for account deletion, such data will be retained for 30 days after the Website is shut down before it is deleted.
Date of birth	We do not store this information. This is processed device side only.
IP address	We do not store this information. We process this momentarily and this is automatically deleted once location of user has been detected.
Email address	For as long as you subscribe to receive newsletters from us. If you unsubscribe, your data will be deleted within 30 days.
Cookies information	Stored for 1 year by Google Analytics.
Pre-registration event data	Stored until the end of the event and for 7 days thereafter, or until account deletion upon your request, at which point it will be deleted within 7 days, whichever is earlier.
Website and Game
Account registration data	Stored for the lifetime of your LIP Account or until account deletion in accordance with your request, upon which it will be deleted within 30 days. Where you do not request for account deletion, such data will be retained for 30 days after the Website is shut down before it is deleted.
Game
Analytics and profiling data (Appsflyer) Data analytics data Anti-cheating data Crash-related information Microphone signal Game performance analysis data Device class analysis data Buried data analysis Statistics and analysis data Network performance data Device performance data Game data Log data Optimisation data Transaction data Game behaviour data Account Security Information	Stored for the lifetime of your use of the Game or until account deletion in accordance with your request, upon which it will be deleted within 30 days, whichever is your earlier. Where you do not request for account deletion, such data will be retained for 30 days after the Game is shut down before it is deleted.
Game survey data Survey information (via IMUR) Email notification data Events and quality analysis data	Stored for 90 days or deleted within 30 days from your request, whichever is earlier.
Real time voice data and voice file	We do not store this information. This is processed momentarily only.
Chat data	Public chat data: We do not store this information. This is processed momentarily only. Private chat data: If the other user has seen the message, the data will be deleted immediately and is not stored on our servers. If the user has not seen the message, it will be saved on our server after it is sent and until the other user has read the message, or deleted within 30 days upon your request, whichever is earlier.
H5 data	Stored for 1 year and then deleted automatically after or deleted within 30 days of your request, whichever is earlier.
Data subject request ticket information	Stored for 3 years.
*For Events*
Identifying Information	Stored for one year after the end of the Event, or deleted within 30 days from the receipt of your deletion request. In case those information are necessary to maintain the record of the participation to the Event, such will be kept until Service is shut down.
Device and Network Information Gameplay and Interaction Data	Stored for one year after your last interaction with the Event, or deleted within 30 days from the receipt of your deletion request. In case those information are necessary to maintain the record of the participation to the Event, such will be kept until Service is shut down.
Financial Information	Stored for seven years after the completion of the transaction, or deleted within 30 days from the receipt of your deletion request.
Media and Additional Data	Stored until the Service is shut down, or deleted within 30 days from the receipt of your deletion request.
Survey Information	Stored for up to 1 year.
Identifying Information	Stored for one year after the end of the Event, or deleted within 30 days from the receipt of your deletion request. In case those information are necessary to maintain the record of the participation to the Event, such will be kept until Service is shut down.

7. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Services. 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.

Access

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

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in Section 3 (How We Process Your Personal Information). We will provide further information to you about transferring this data if you make such a request.

Correction

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

Erasure

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

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. 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 Services 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.

Advertising

You may choose to stop receiving personalised advertising or marketing promotions from us by following the opt-out instructions included our emails, or by contacting us.

8. Contact

You can reach us using our online form for submitting data privacy related request and question here. For any questions not covered by the form, please email: dpo_uamo@proximabeta.com

Mailing Address:

International Privacy & Data Protection Centre

79 Robinson Road, #07-01

Singapore

068897

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

9. Changes

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

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.

SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS

Some jurisdictions’ laws contain additional terms for users of the Services, 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.

Algeria

By using the Website and Service, you give us your consent for the collection, storage, treatment and use of your personal information, and transfer of your personal information to a third party (such as local cloud providers to back up your data or our affiliates around the world to help us deliver the Website and Service) located in Singapore and the People’s Republic of China (as described in the Privacy Policy) where it is manually and electronically treated.

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 us with your personal information and by using the Website and Service, 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 Website and Service.

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Website and Service. 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 Website and Service, including social media integration and in-Service 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 this 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 this 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 Singapore and the People’s Republic of China.

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 and Service 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 AND TRANSFERRING TO COUNTRIES OTHER THAN BRAZIL, 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. 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 Service 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 set out in Section 8 (Contact)

Egypt

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

You also acknowledge your consent to receiving marketing messages from us, whether through e-mails or pop-ups or other such means.

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

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).

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

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 Website and Service.

In the event we fail to maintain the confidentiality of your personal information in the Website and Service, we will notify you through the contact information provided by you or via the Website and Service, 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 Website and Service.

By accepting this Privacy Policy, 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 Website and Service.

By accepting this Privacy Policy, 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 People’s Republic of China.

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 of 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.

Kingdom of Saudi Arabia

How We Store and Share Your Personal Information

Your personal data may be transferred abroad and to third parties as follows:

Identity of the overseas recipient	Location of the recipient (or as otherwise stated in the recipient’s privacy policy)	Purposes of use of Personal Information by the recipient	Items of Personal Information to be provided
Appsflyer (https://www.appsflyer.com/legal/privacy-policy/)	Belgium and Ireland	Perform data analytics and app attribution analysis.	Analytics and profiling data
Aceville Pte. Ltd. (cloudlegalnotices@tencent.com)	Singapore	Storage of personal information	All personal information collected
Midaspay HK (Centauri Technology Pte. Ltd.)	Singapore	Enable you to view your purchase history, to restore purchased items and to ensure security of the service.	Transaction data Account security information

Transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.

Your Rights

You have the right to be informed about our processing of your personal information, which we satisfy by providing this Privacy Policy to you. You also have the following rights as further described in Section 7 (Your Rights): the right to access, correction, erasure, restriction and to withdraw consent. Unless otherwise stipulated by law in Saudi Arabia, you will not be required to pay any fees in return for exercising these rights. We will respond to your request within 30 days of receiving it. Where you wish to make such requests, please contact us as set out in Section 8 (Contact).

You also have a right to lodge a complaint with the Saudi Data and Artificial Intelligence Authority by contacting them directly. Their website is accessible at: www.sdaia.gov.sa

Data Destruction

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.

Kuwait

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Macau SAR

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Website and the Service to you. As a Macau SAR data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Website and Service, 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 requestor 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 requestor 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 contacting us as set out in Section 8 (Contact). However, this may affect our provision of the Website and Service 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_uamo@proximabeta.com

Mexico

Some of the purposes of processing stated above are for voluntary purposes, including to show you personalised recommendations. We may also use your personal data for the voluntary purpose of sending information to your email or SMS 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 Service 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 set out in Section 8 (Contact).

Morocco

We collect information for purposes strictly necessary for the proper use of the Website and the Service.

By accepting this Privacy Policy, you explicitly accept that your personal data may be subject to processing by the Website and the Service.

Kindly note:

· the identity of the Data Controller is Proxima Beta Pte. Limited, email: dpo_uamo@proximabeta.com.

· the purposes of the processing for which the data is intended are set out in the table in the section “How We Use Your Personal Information”.

· recipients or categories of recipients are set out in the second paragraph of the section “How We Store and Disclose Your Personal Information”.

· whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to the section “How We Use Your Personal Information” and the section “Your Rights”.

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 Website and Service.

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, etc. pursuant to applicable laws such as 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: dpo_uamo@proximabeta.com

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 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 4 (How We Store and Share Your Personal Information)

Qatar

If you are using the Website and Service in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Republic of Korea

Collection and Use of Personal Information

We collect your personal information for the purposes described in this Privacy Policy. Personal information that we collect from Republic of Korea is stored in and processed on our server located in Singapore.

With regards to the legal basis of processing personal information included in Section 3 “How We Process Your Personal Information,” the following legal provisions under the PIPA applies:

(for consent): we use this information pursuant with your consent, pursuant to Article 15(1)(1) of the PIPA.
(for complying with legal obligations): we use this information where necessary to comply with a legal obligation pursuant to Article 15(1)(2) of the PIPA.
(for contractual necessity): we use this information where necessary to perform our contract with you to provide our Services, pursuant to Article 15(1)(4) of PIPA.
(for legitimate interest): we use this information where it is in our legitimate interest pursuant to Article 17(1)(2),15(1)(6) of PIPA.

Third-Party Provision of Personal Information

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

Legal Grounds

Name of Recipient (and contact information)

Types of Personal Information provided

Purpose of Use by Recipient

Period of Retention and Use by Recipient

Legitimate interest – PIPA Art. 17(1)(2), 15(1)(6)

Appsflyer

(https://www.appsflyer.com/legal/privacy-policy/)

Analytics and profiling data

Perform data analytics and app attribution analysis.

In accordance with the Appsflyer privacy policy

Legitimate interest – PIPA Art. 17(1)(2), 15(1)(6)

Midaspay HK (Centauri Technology Pte. Ltd.)

dpo@centauriglobal.com

Transaction data

Account security information

Enable you to view your purchase history, to restore purchased items and to ensure security of the service.

For the data retention period specified under “Data Retention”

Delegation of Personal Information

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
Midaspay HK (Centauri Technology Pte. Ltd.)	Enable you to view your purchase history, to restore purchased items and to ensure security of the service.
Aceville Pte. Ltd.	Storage of personal information

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

*Legal Grounds*	*Recipient (Contact Information of Information Manager)*	*Country or Region 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*
PIPA Art. 28-8(1)(3) Delegation and Retention for Contract Performance	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”
PIPA Art. 28-8(1)(1) Consent of the Data Subject Legitimate interest – PIPA Art. 17(1)(2), 15(1)(6)	Midaspay HK (Centauri Technology Pte. Ltd.) dpo@centauriglobal.com	Singapore	Transferred via information and communications network at the time of service use	Transaction data Account security information	Enable you to view your purchase history, to restore purchased items and to ensure security of the service.	For the data retention period specified under “Data Retention”
Legitimate interest – PIPA Art. 17(1)(2), 15(1)(6)	Appsflyer (https://www.appsflyer.com/legal/privacy-policy/)	Belgium and Ireland	Transferred via information and communications network at the time of service use	Analytics and profiling data	Perform data analytics and app attribution analysis.	In accordance with the Appsflyer privacy policy

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)

Your Rights

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, or objecting to or requesting an explanation on an automated decision concerning 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. Pursuant to Articles 15(3) and 17(4) of the PIPA, we consider the following factors set forth in Article 14-2 of the Enforcement Decree of the PIPA when using or providing to a third party additional personal information without your consent:

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.

Measures to Ensure Safety of Personal Information

We implement the following measures to ensure safety of your personal information:

1. Managerial measures: establishment and implementation of internal management plan, operation of dedicated organization, regular employee training

2. Technical measures: management of access rights to the personal information processing system, installation of an access control system, encryption of personal information, and installation and renewal of security programs

3. Physical measures: access control of computer rooms, data storage rooms, etc.

Domestic Privacy Representative

Pursuant to the Article 32-5 of Network Act and Article 31-2 of the amended PIPA, the information regarding the domestic agent is as follows:

Name: Kite Bird Korea Yuhan Hoesa (Representative: Wang Si Min)
Address: 25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Republic of Korea
Telephone: +82-2-2185-0926
Email: specified in Section 8 (Contact)

Contact

Data Protection Department, responsible for the management and safety of your personal information
Telephone: +82-2-2185-0926
Email: specified in Section 8 (Contact)

Remedies for Infringement of Rights and Interests

In order to seek remedies for personal information infringement, you may file an application for dispute resolution or consultation with the Personal Information Dispute Mediation Committee, the Korea Internet & Security Agency's Personal Information Infringement Reporting Center, etc. In addition, you may contact the following institutions for other reports and consultations on personal information infringement:

1. Personal Information Dispute Mediation Committee: (no area code required) 1833-6972 (www.kopico.go.kr)

2. Personal Information Infringement Report Center: (no area code required) 118 (privacy.kisa.or.kr)

3. Supreme Prosecutors’ Office: (no area code required) 1301 (www.spo.go.kr)

4. National Police Agency: (no area code required) 182 (ecrm.cyber.go.kr)

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 accepting this Privacy Policy, you consent to the collection, use and disclosure of personal data as set out in this Privacy Policy, including cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, the locations specified in Section 4 (How We Store and Share Your Personal Information). In situations where consent is not obtained, Proxima Beta collects, uses, or discloses personal data in accordance with an exception under the Personal Data Protection Act 2012 or as required or authorized by any other applicable law.

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 here.

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 the button to proceed, you consent to the terms and conditions of 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 Website and Service.

Serbia

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

Thailand

By accepting this Privacy Policy, 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 Service.

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 Service.

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.

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

Türkiye

You have legal rights, which are set forth in Article 11 of the Turkish Law on Personal Data Protection Law (“DPL”), in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

learn whether or not your personal data has been processed;
request information about processing if your personal data has been processed;
learn the purpose of processing of your personal data and whether they have been used accordingly;
know the third parties in the country or abroad to whom personal data has been transferred;
request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and
demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

Identity of the overseas recipient	Location of the recipient (or as otherwise stated in the recipient’s privacy policy)	Purposes of use of Personal Information by the recipient	Items of Personal Information to be provided
Appsflyer (https://www.appsflyer.com/legal/privacy-policy/)	Belgium and Ireland	Perform data analytics and app attribution analysis.	Analytics and profiling data
Aceville Pte. Ltd. (cloudlegalnotices@tencent.com)	Singapore	Storage of personal information	All personal information collected
Midaspay HK (Centauri Technology Pte. Ltd.)	Singapore	Enable you to view your purchase history, to restore purchased items and to ensure security of the service.	Transaction data Account security information

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws) and storage of your personal information, as described in the privacy policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

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 username and email address. This information is collected directly from you and your device.
Characteristics of protected classifications under California or federal law such as date of birth. This information is collected directly from you in the context of being our consumer.
Geolocation information such as your country location and IP address when you set up your profile and choose to provide this information for the Services. This information is collected directly from you and your device.
Account log-in information, including the username and password used to access your account.*

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

To provide you with the Services and maintain your LIP Account
To age gate users.
To ensure the correct version of the Services is shown to users.
To process surveys.
To improve our Services, including the functionality of the Game.
For security and verification purposes, including to prevent and detect fraudulent activity.
To monitor the success of our advertising and marketing campaigns and for ad attribution.
To send you news, updates, promotions and offers about the Game.
To enable you to participate in Events.

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.

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;
Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted advertising or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects; 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. 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.

*What information do we need to be able to provide the Services?*	Website · If you register for a LIP Account for the Services, we will need some information from you to set this up. This includes information such as your username, email address and password. Depending on your use of the Service 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 sign up newsletters, offers or updates about the Game, we use your email address to send you such information. · We use your IP address and your country location to determine whether the Game is available in your country / region. · We use cookies and other similar technologies to collect information about you when you visit the Website. Game · 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 information, device specifications, as well as app- and OS-generated identifiers). · In certain jurisdictions, the Game also allows players to communicate directly with each other via the text chat and audio chat functions. If you wish to participate in our surveys, we will process survey information and survey device data, IP address and browser version, with your consent to better understand our users and to improve the Game. · To provide you with Events, we process various information, such as identifying information, device and network information, financial information, gameplay and interaction data, media and additional data, and survey information.	More Information.
*How will we use your information?*	· We use your information to set up your account, enable you to use the Services, 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, participate in surveys and to send you announcements about the Game 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 (e.g. Appsflyer) and work with our affiliates to help us deliver the best possible experience. · 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 Services (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?*	· 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 Services in Singapore. We also have support, engineering and other teams who may support the Services, including from Singapore and the People’s Republic of China (“PRC”). · We use a third-party service, Google Analytics, to collect cookies information. Google maintains servers around the world and your information may be processed on servers located outside of the country where you live. · For EEA and UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses 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 Services, 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.

Jurisdiction	Representative	Address	Contact details
UK	Image Frame Investment (UK) Limited	4^th Floor 80 Strand, London, United Kingdom WC2R 0RL	dpo_uamo@proximabeta.com
EU	Proxima Beta Europe B.V.	Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands	dpo_uamo@proximabeta.com
Korea	Kite Bird Korea Yuhan Hoesa	25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Kore	dpo_uamo@proximabeta.com
Serbia	Karanovic & Partners o.a.d. Beograd	Resavska 23, Belgrade, 11000, Serbia	local.representative@karanovicpartners.com
Thailand	Tencent (Thailand) Company Limited	8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand	dpo_uamo@proximabeta.com
Türkiye	Özdağıstanli Ekici Avukatlık Ortaklığı.	Nidakule Ataşehir Kuzey Begonya Sok. No:3 Kat. 17 D: 162 34746 Ataşehir / İstanbul, Türkiye Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-Service conduct, suspensions, investigations, civil or criminal complaints.	turkeydatarep_proximabeta@iptech-legal.com

1. Cookies

2. Children

3. How We Process Your Personal Information

4. How We Store and Share Your Personal Information

5. The Security of Your Personal Information

6. Data Retention

7. Your Rights

8. Contact

9. Changes

10.Language

11.Our Representatives in Certain Jurisdictions