Arena Breakout: Infinite

Official Website and Game

Privacy Policy

Last Updated: [ July 5 ] 2024

Thank you for using Proxima Beta’s (as defined below) products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to the Arena Breakout: Infinite website (“Website”) and game (“Game” and together with the Website, the "Services”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us.

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”).

SUMMARY

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

What information do we need to be able to provide the Services?

Website

  • If you use the Website to pre-register for the open beta test (“OBT”) for the Game, we will collect your email address. If you are selected for the OBT, we use your email address to contact you about the OBT and your LEVEL INFINITE PASS account (“LIP Account”) information to enable you to log in to play the Game.
  • 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 OBT for 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.

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.

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.

  1. 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

Sri Lanka

18

Switzerland

14

Thailand

20

Tunisia

18

Türkiye

18

United Arab Emirates

21

United Kingdom

13

United States

13

  1. 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 OBT for the 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; and
  • pre-register you for the OBT so that you can receive news and updates about the OBT.

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.

Website and Game

Account registration data: When you register for a LIP Account, we collect your email address, username and password.

We use this information to contact selected users for the OBT and allow you to register and create and login to your account for the Services.

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

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.

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.

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.

  1. 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:

  1. 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. 

  1. 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.

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

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

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.

  1. 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.

  1. Contact

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

Email: dpo_uamo@proximabeta.com

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.

  1. 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.

  1. Language

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

INFORMATION FOR PARENTS

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

What personal information does Arena Breakout: Infinite process?

Arena Breakout: Infinite is a survival shooting mobile game. In the game, players will roleplay as a soldier to participate in a virtual peacekeeping exercise, and they will enter into a large, open map scene. At the same time, they can carry different weapons to fight against AI-driven enemies. Players can collect materials, survive and cooperate, and complete challenging tasks in the map scene in the form of single player or team cooperation.

If your child successfully signs up to Arena Breakout: Infinite, this will result in the collection and sharing of certain personal information, for example:

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

Does Arena Breakout: Infinite process personal information differently for children?

Yes, free text chat and audio chat functions are disabled for minors in certain jurisdictions.

Why is my consent required?

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

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

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

What if there are changes to Arena Breakout: Infinite in the future?

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

Will you retain my personal information?

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

What if I do not consent?

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

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

You can withdraw your consent or delete your child’s account by contacting us. You can also request a copy of your child’s personal information at any time.

  1. Our Representatives in Certain Jurisdictions

Jurisdiction

Representative

Address

Contact details

UK

Image Frame Investment (UK) Limited

4th 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

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 

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

 

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.

Kingdom of Saudi Arabia

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 this Privacy Policy, including (without limitation) for the purposes of showing you personalized advertising when you use the Website and the Service.

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.

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:

 

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.

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

 

Philippines

You are entitled to the following rights:

 

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

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.

Serbia

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

Singapore

By 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

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.

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:

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):

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 and to restore purchased items

Transaction data

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:

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

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.

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.