We(“NEXELON”, “us,” or “our”) are committed to protecting and respecting your privacy.
The term “personal data(“personal information”, “information”)” may include your name, device ID, e-mail address, date of birth, gender, your game preferences, for instance. But anonymous data, which we cannot relate to you, does not qualify as “personal data”.
We process personal data only when necessary for the performance of a contract with you, for compliance with a legal obligation to which we are subject, or based on our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms for which require the protection of your personal data.
1. HOW WE COLLECT INFORMATION
1.1. Information we collect directly
We collect personal data and other information you provide directly. It is entirely your choice to provide the data we requested.
We may collect your personal data when you use our services or when you provide feedback about our services. This data includes.
● Information you provide when you request information or support from us or purchase a product or service from us, including information necessary to process your orders with the relevant payment merchant, which may include the amount of any transaction, but will not include your financial information, which will only be submitted directly to the payment merchant under secure protocols; and
● Information excepting the account data you provide to us when participating in tournaments, contests, at online events, or responding to surveys, e.g. your phone number or address;
1.2. Information we collect indirectly
We indirectly collect personal data and other information through interactions when you use our games, websites, and other services.
This information may include, but is not limited to, device information(device ID, OS, OS version, ADID, UDID, language, and country settings), connection record(IP address, connection IP, login time and dates), PC specification, cookie, anonymized browser, data collected through automated electronic interactions, application usage data, statistical and aggregated information.
Statistical or aggregated information does not identify a specific person directly, but it could be derived from both personal data and information. We can aggregate personal data to calculate the percentage of users who use our games in a particular country, for example. If other information is combined with personal data, we will identify and process the combined information as personal data.
1.2.1. Game-related information
We may need to collect, store and use various information about your activity in our games in order to provide you with efficient services.
This, game-related information, includes your in-game identifier, which for most of our games is known as account ID or email address, as well as what is usually referred to as game statistics.
By game statistics, we mean information about your preferences or progress in the games, participation, and performance in clans, and frequency of playing.
1.2.2. Device information
While you are installing our games and using our game services, we collect, store and treat information about the device you are using, including what type of device it is, what kind of hardware and operating system you are using, unique device identifiers, android ID, IP address, connection IP, PC specification and crash data, in order to fix crashes and other technical issues that may arise. Whether we collect some or all of this information often depends on what type of device we are using.
1.2.3. Information required for fraud and violations detection
We may also collect certain data such as IP address, a username that could be required for investigation and prevention of cheating in the game, and EULA violations.
This data, being used only for the purposes of investigation and prevention of frauds and cheating in the game will be deleted 1 year after its collection unless the data can be used to prove that cheating has occurred. If the data can be used to prove that cheating or another fraud or EULA violation has occurred, we will store the data for longer than 1 year for the establishment, exercise, or defense of legal claims during the applicable period of filing a complaint.
The specific data stored for this purpose may not be disclosed to both you and any third parties, because the disclosure will compromise the mechanism through which we detect, investigate and prevent frauds and cheating in the game, as well as other EULA violations.
1.2.4. Information from publicly available online resources
We may use the information made publicly available on Facebook or YouTube to find out your opinion about our games or services.
This, collecting such data, could be carried by NEXELON independently, or can be carried by our marketing partners making analysis of public sentiments on various issues.
1.2.5. Information from our partners
In some cases, we could receive your personal data as a data processor, which means that your personal data is controlled by our partners and we only use it in accordance with their instructions and applicable laws. We will use this data to fulfill obligations under EULA, improve services, or comply with legal obligations.
We may receive a part of your credit card number, information about your credit card issuer from our payment partners when you purchase online and mobile game items, virtual cash with your credit card.
We also receive and use your information through other platforms such as Google Play, PlayStation4, Xbox, Steam, etc. so that you can play our games through these platforms.
We have registered certain games-related group accounts and pages at Kakao, Facebook, Naver, Line and other social networks to do better communicate with our game players. So, we may get information relating to your profiles on social networking sites. e.g., character name, and date of birth.
2. HOW WE USE YOUR INFORMATION
We need to process your personal data to perform the contract with you. We will use your personal data, unless otherwise prohibited by law, for the following purposes:
● to allow your installation of our games, provide the services, verify and confirm your payments;
● to check your account or communicate with you about transactions and send you information about features on our websites or changes to our policies;
● to provide game update information, game patches, and fixes, other similar communications; and
● to send you gifts and awards, to which you may be entitled as a result of winning an online or offline competition, etc.
2.1. Communication purposes
We will use your personal data for our legitimate interests and advertise our products and services in accordance with this policy.
Once you create an account we may use your email address, nickname, IP address, connection IP, country settings in order to send you personalized marketing emails, messages, targeted in-game offers about our games.
2.2. In-game offers
We will send you in-game offers that are useful to you by using the game-related information we collected.
2.3. Services improvement purposes
We will analyze your personal data to find out how to improve our game services to make them more suitable and interesting for you and other players. Also, we may ask you to respond to our services-related questionnaires, and you always have the choice about whether to respond to them and which information you will provide.
2.4. Fraud and EULA violations detection
We may use your personal data required for investigation and prevention of cheating in our game and violations of EULA or policies for the purposes of investigation and prevention.
3. HOW WE SHARE YOUR INFORMATION
We may share your personal data for the performance of the contract with you, the compliance with a legal obligation, or our legitimate interests with the following categories of third parties.
3.1. Payment partners
We may share your date of birth, email address, IP address, or information about in-game purchases requested by you on NEXELON's websites, and other information you provide to us for the purpose of fulfilling your purchase or withdrawal requests.
3.2. Data storage partners
We may store your personal data using third-party data storage services such as Google Cloud Platform(GCP), Amazon Web Services(AWS), Microsoft Azure(Azure).
3.3. Research partners
We may provide access to some of your data, such as game statistics, to provide marketing-related and other research. We also may share anonymous data with our partners unless your personal data is necessary for the requested services or research.
3.4. Customer service partners
We may share your personal data with third parties to provide you with customer services and support effectively. Such partners may get access to your personal data only for the purposes mentioned above. For more information about these partners, please contact us.
3.5. Publicly available information
Our websites may have bulletin boards, forums where users can exchange ideas and communicate with each other. When you post a message to a board, forum, please be aware that your message and the information about you are being made publicly available online. Therefore, please do not include any data in your nickname that will personally identify you.
3.6. Sharing anonymous information
We may share anonymous data, which does not directly or indirectly disclose your identity, and aggregated information such as game statistics, categories of users which do not identify and that cannot be used to identify any individual user with our advertising partners. We may also allow our advertisers to collect and aggregate anonymous data about our services and they may share the information with us. They may also collect this information through the use of tracking technologies like cookies and web beacons. This enables us to develop and deliver targeted advertising in our services and on the websites of third parties so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you.
4. HOW LONG WE KEEP YOUR INFORMATION
Generally, we will delete your personal data after you request your account deletion and the grace period of 30 calendar days, during which we can restore your account, expires. However, considering the complexity and number of requests, it can be extended for another one month sometimes.
When we no longer need to keep your personal data, we will delete it from our data processing server.
We will also delete your personal data immediately after a request to unsubscribe for the purposes of resolving unwanted customer complaints or disputes. But sometimes it may take longer than 15 days depending on the individual operational policy of the game you play.
5. COOKIES AND SIMILAR TECHNOLOGIES
Cookies are essentially small data files placed on your computer, mobile phone, tablet, or other devices that allow us to record certain pieces of information whenever you visit our websites or interact with our services. Most browsers allow you to block and delete cookies.
You can refuse all cookies, confirm each time a cookie is saved or permit all cookies by going to [Tools] >[Internet option] >[Security] >[Custom setting], or by using the settings or options function on mobile devices. However, if you do that, some of our services may not work properly.
A web beacon is a piece of code embedded in our services that collects information about your engagement on that web page. The use of a pixel allows us to record, for example, that you have visited a particular web page or clicked on a particular advertisement, or installed particular applications. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Mobile device identifiers.
We may share the advertising identifier associated with your mobile device or tablet. We use the Apple IDFA only as permitted by Apple, and we use the Google Advertising ID only as permitted by Google. An advertising identifier is assigned, and ad tracking is turned on, by default on your mobile device. You may limit the use of or reset your advertising device ID using the privacy settings on your mobile device. In some cases, you may need to reset the operating system to reset the advertising device ID
We may also use Google Analytics to collect information regarding your behaviors to get the demographics of our services. For more information about Google please visit http://www.google.com/policies/privacy/partners/. You can opt-out of Google’s collection and processing of data generated by your use of the services by going to http://tools.google.com/dlpage/gaoptout.
Do Not Track.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to the online services you visit. Note, however, there is no industry consensus as to what website and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
The use of these technologies falls into the following categories;
Related to performance.
We may use technologies to collect information about how our services are performing. We may use the information to compile reports and to help make improvements to our services.
Related to functionality. We may use technologies that allow us to offer you enhanced functionality when accessing or using our services. This may include identifying you when you sign in to our services or keeping track of your specified preferences, interests, or past items viewed;
Related to research.
We may use technologies to collect information about how you use our services, including the total number of users that use our services and the types of devices they use; and
Related to advertising. We may use technologies to deliver content, customize the advertising relevant to your interests in our services or websites.
We fully know that we have a special obligation to protect children’s information. Our games are intended for persons aged over 16 in EU or aged over 13 in U.S., otherwise defined in your country of residence or older than such applicable age.
Children in Europe.
We make reasonable efforts to verify that consent is given by your parent or legal guardian and if we collected personal data from you without their consent, we will delete it immediately.
We do not collect personal data of minors under 16 who are residents of California without their affirmative authorization, or the affirmative authorization of their parent or legal guardian for minors under 13.
8. INTERNATIONAL DATA TRANSFERS
9. YOUR RIGHT
9.1. General rights
Right of access.
You may have the right to confirm that we are processing and gaining access to your personal data. Should you have any questions regarding the processing, or would you like to have more insight into the personal data that we process, you are always welcome to contact us, and we will provide you with further information.
Right to rectification.
You may have the right to request that we correct data that we have inaccurately stored. You may also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to be forgotten.
You may have the right to request us to permanently delete your personal data. You can make such a request if you, for example, believe that the personal data are no longer necessary in relation to the purpose for which the personal data were collected or otherwise processed. The deletion of personal information can be processed through our customer center (Email inquiry), or by selecting to cancel the membership or delete the account from the in-game menu. However, if personal information is destroyed in such ways, related information generated and accumulated while using the company's game service may be destroyed as well.
Right to restrict the processing activities. You may have the right to restrict our processing activities. If you choose to restrict our processing activities as relates to providing our services, you might not be able to use them.
Right to data portability.
You may have the right to request from us that we send your personal data to you in a structured, commonly used, and machine-readable format, and transmit your personal data to another controller.
Right to object.
You may have the right to object to our processing of your personal data. If you choose to object to our processing activities, you might not be able to use all of our services.
Right to lodge a complaint with a supervisory authority.
If you are unsatisfied with the way we treat your personal data, you may reach out to us at all times to solve the issue. Also, you always have the right to lodge a complaint with a supervisory authority.
Right to withdraw consent.
Where our processing of your personal data is based on your consent, you may have the right to withdraw such consent at any time. The withdrawal of your consent will not affect the lawfulness of the processing based on consent before its withdrawal.
If you would like to exercise any of the rights listed above, please contact us at email@example.com
9.2. Your choices
10. CHANGES TO THIS POLICY
11. CONTACT US
Title: Data Protection Officer
Name: OK HANG YOON
Address: 1st Fl, WEMADE Tower, 49, Daewangpangyo-ro 644, Bundang-gu, Seongnam-si, Gyeonggi-do, 13493, Korea.
Effective Date. 2021.09.24