Terminull Brigade

Closed Beta Test

Game, Website and Events

Privacy Policy

Last Updated: 22.12.2024

Thank you for using our 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 Terminull Brigade’s Closed Beta Test (“Game”), its official website (“Website”) and its related interactive activities and events (“Events”) (together, the “Service”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited.

SUMMARY

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

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

  • If you register to use the Service using Level Infinite Pass, then we will need some information from you to set this up. This includes an email address or password. We will generate an Open ID, which is an internal ID for your account. 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.
  • To maintain the smooth operation of the Service (which includes activities such from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information (such as IP address, connection speed, device specifications, as well as app- and OS-generated identifiers).
  • If you choose, you can provide other information to personalise your experience of the Service or enable Service features. This includes language or location.
  • If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns.

More Information.

How will we use your information?

  • We use your information to set up your account, enable you to use the Service, localise the Service experience, enable interaction between users of the Service, save your progress, ensure the safe and secure operation of the Service, address bugs, optimise and improve the Service, protect users, monitor our marketing initiatives, resolve user queries, and to comply with our legal obligations and enforce our legal rights.

More Information.

Who do we share your information with?

  • We might use third parties 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 Service (i.e., to fulfil the purpose(s) described above).
  • In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.

More Information.

Where do we process your information?

 

  • Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.
  • We have servers for the Service in Singapore and the United States. We also have support, engineering and other teams who may support the Service, including from Singapore and the United States.

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 Service, 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.

 

Events

Our Services offer a dynamic and engaging experience through a variety of interactive and frequently updated activities, collectively known as "Events." These Events come in different forms, including:

By participating in these Events, you may receive various prizes and rewards, such as in-game currency, exclusive skins, special items, titles, experience boosts, cash prizes, gaming hardware, game codes, merchandise, event tickets, recognition, exposure, or other event-specific rewards.

 

 

 


 

 

Welcome to Terminull Brigade™!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with Terminull Brigade’s Closed Beta Test (“Game”), its official website (“Website”) and its related interactive activities and events (“Events”) (together, the “Service”), 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 Service. 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 Service. By using the Service, 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 Service is Proxima Beta Pte. Limited (“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at projectr_dpo@levelinfinite.com

1.                Children

Children must not use the Service for any purpose.

By children, we mean users under the age of 13 years old in relation to Canada and the United States; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

Other than as provided above, we do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.

Region in which the user is located

Minimum age of the user

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

18

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

14

Sri Lanka

18

Switzerland

14

Taiwan

20

Thailand

20

Tunisia

18

Türkiye

18

United Arab Emirates

21

United Kingdom

13

United States

13

Vietnam

16

 

2.                How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

Personal Information

Use

Legal Basis (where applicable)

Information you provide to us (either directly or through a third party) 

For the Website

 

Website survey and subscription information: Steam ID, Open ID or nickname, age or date of birth, email address country, game habits, experience and preferences (such as recently played games, game duration and favourite game categories and experience), system specifications, and any other information you choose to provide as part of your survey and subscription responses

We use this information to better understand players' gaming habits and feedback on their experience with the Service, and to determine your eligibility and suitability to participate in the Game.

We collect this information with your consent.

For the Game (where available in your jurisdiction)

Login via Level Infinite Pass: UID, token, email address, password

We use this information to allow you to register and create your account for the Service in accordance with your request, log in to the Service and participate in game activities and receive notifications of the Service.

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

Nickname

We use this information to create your account for the Service in accordance with your request.

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

Region location (manually selected by you)

We use this information to:

  • set up your use of the Service on a regional server; and
  • improve gameplay.

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

For Events

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, 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 use this information to provide an engaging experience.

 

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.

Events Survey Information: Any information requested as part of the survey (e.g. email, country or region of residence, gaming habits and preferences, Steam ID and other games ID, gameplay frequency, favorite 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; and
  • send you news, events and promotions relating to the Event if you wish to receive such information.

We collect this information you’re your consent.

Personal Information categories described in this table and this Addendum

To maintain records (other than described in the Uses described above).

Necessary to perform our contract with you to participate to the Event.

 

We process this information to comply with our legal obligations.

Information generated as part of the Service

For the Website

IP address

We use this information to collate statistics on page views.

It is in our legitimate interests to use this information to collate statistics of visits to the Website.

Activity analysis information:  IP address, device information like (such as Android version, iOS version and CPU and similar data).

We use this information to measure the health and performance of and any issues with the Website.

It is in our legitimate interest to understand the health and performance of the Website.

For the Game

IP address, country/region

We use this information to allow you to use the Service and connect to our servers.

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

Anti-cheat information: Game logs (account information), device information (gameplay data, location information, device information, identity verification information), Open ID, nickname, IP address, user generated text content

We use this information for anti-cheating purposes, including to detect and observe cheating behaviours and monitor the presence and operation of suspected cheating activity or anomalies.

It Is in our legitimate interest to use this information to detect and prevent cheating in the Service.

Diagnostic and crash reporting information: OpenID, IP address, MAC address, operating system, CPU, GPU, memory, resolution, network status, process name, crash time, and crash dump

We use this information for diagnostic and crash reporting, and identifying, analyzing and resolving issues such as crashes and latency issues.

It is in our legitimate interest to optimize your experience in the Service.

Performance monitoring and analysis information: OpenID, IP address, SDK version, system time, system startup time, network status, PC hardware information (OS, CPU, GPU, screen resolution), client performance data (CPU usage, GPU usage, memory usage, FPS)

We use this information for performance monitoring and analysis.

It is in our legitimate interest to optimize your experience in the Service.

Data access support information: Open ID, nickname, game level, game server area ID, item ID and counts, mail ID, reg time, login time, logout time, online status, ban status and reasons

We use this information to allow for real-time data access and operation between various operating systems.

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

Game runtime data information: Server ID, System time, account information (OpenID, nickname), game level, gameplay statistics

We use this information to process and store your game runtime data.

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

Data analysis and reporting information: Server ID, system time, system startup time, network status, account information (Open ID, nickname), game level, PC hardware information (OS, CPU, GPU, screen resolution), client performance data (CPU usage, GPU usage, memory usage, FPS), IP address, gameplay statistics

We use this information to better understand our players’ gaming behaviours and to monitor the success of our advertising campaigns.

 

It is in our legitimate interest to optimize your experience in the Service.

Voice chat information: Open ID, system time, IP address, MAC address, SDK version, Network Type

 

We process this information to facilitate your real-time voice chat with users. We also process and review this information if we suspect any inappropriate behaviour.

 

We do not store this information on our servers.

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

Text chat information: Open ID, text chat data

We process this information to provide you with the functions of lobby chat (public text chat, team chat and message chat (private text chat).

 

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

Customer Support: 

  • Game account and contact information (including your nickname, profile picture, open ID, country selected by you during registration, login channel, social media account, mobile phone, email address, registration time);
  • Login status verification information;
  • Device information;
  • Game data: Game character information (including your role name and role ID, game data and records, frequency of playtime, game history), and in-game data (including items, purchase and top-up information, penalties, activities, game match data, in-game friends);
  • Customer service log data (including Open ID, ticket date, type of request);
  • Feedback on steam store;
  • Any other details/information (including any documents/media) that you choose to provide to us as part of your ticket, query or review

We use this information to improve our services and provide troubleshooting, such as addressing and remediating technical issues and bugs.

Necessary to perform our contract with you to provide and support the Service.

For 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, behavioral 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.

 

3.                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 Service in Singapore and the United States. The servers applicable to your use of the Service may depend upon your location. We also have support, engineering and other teams who may support the Service, including from Singapore and the People’s Republic of China.

 

Only where necessary will we share your personal information with third parties. Situations where this occur are:

4.                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 Service or otherwise via the Internet; any transmission is at your own risk.

 

5.                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

For the Website

IP Address

 

Activity analysis information

 

Website survey and subscription information

 

Stored for the duration of the Service, or deleted within 30 days if you request for account deletion or the Service is shut down.

For the Game

Login via Level Infinite Pass

 

Data analysis and reporting information

Customer Support

Stored for the duration of the Service, or deleted within 30 days if you request for account deletion or the Service is shut down.

Anti-cheat information

Diagnostic and crash reporting information

Performance monitoring and analysis information

Data access support information

Game runtime data information

Stored for 30 days after the end of the Game. Evidence of penalty will be stored for the lifetime of your use of the Service.

Voice chat information

Text chat information

We do not store this.

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.

 

Events Survey Information

Stored for up to 1 year.

 

6.                Your Rights

Some jurisdictions laws grant specific rights to users of the Service. 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 sending us an email at projectr_dpo@levelinfinite.com .

Portability

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

Correction

You may have the right to correct personal information we hold that is inaccurate. You can access the personal information we hold about you by sending us an email at projectr_dpo@levelinfinite.com.

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Service 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 Service 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.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at projectr_dpo@levelinfinite.com or using the contact details set out below, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at projectr_dpo@levelinfinite.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service 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

If applicable, you may choose to stop receiving personalised advertising or marketing promotions from us when using the Service by contacting us at projectr_dpo@levelinfinite.com

7.                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: projectr_dpo@levelinfinite.com

Mailing Address:

Tencent International Privacy & Data Protection Centre

30 Raffles Place #19-01

Singapore

048622

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

8.                Changes

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

9.                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 TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, 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. Please note that the below only applies to you to the extent the Game, Website and/or Events are available in your jurisdiction.

Algeria 

By using the Service, you give your consent to the collection, storage, treatment and use of your personal information, and transfer of your personal information to third parties or our affiliates to help us deliver the Service, in each case location in the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information). 

Argentina 

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar). While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing your personal information and by using the 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 as described in Section 1 (Children) above, you undertake that you have the consent of your parent or legal guardian to use the Service. 

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when using the 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 Service, such as 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 the Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by the Privacy Policy. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

Brazil

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us as set out in Section 7 (Contact). This may affect our provision of the 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, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY. 

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as specified in Section 7 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

Colombia

Your authorization to process personal information for the 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 specified in Section 7 (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 3 (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 7 (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. 

India 

Where we permit any third parties to collect and use sensitive personal information, we shall use reasonable measures to ensure that the third parties do not further disclose such information to the extent required by applicable laws.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us as set out in Section 7 (Contact). 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. Where the processing of your personal data is not based on consent, our processing is based on certain legitimate uses as permitted under law and in compliance with applicable law. 

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 as described in Section 1 (Children) above, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

In the event we fail to maintain the confidentiality of your personal information in the Service, we will notify you through the contact information provided by you or via the 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 as described in Section 1 (Children) above, you must obtain your parent’s or legal guardian’s consent to use the Service. By clicking “accept”, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

 

The categories of personal information specified in to the jurisdictions specified in Section 3 (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 7 (Contact).

Kazakhstan 

If you are under the age as described in Section 1 (Children) above, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Service. 

By clicking “accept”, you consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information as described in this Privacy Policy. The transfer of your personal information to third parties, which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore and the United States. 

In the event of any discrepancy or inconsistency between the English version and the Kazakh version of this Privacy Policy, the Kazakh version shall prevail. 

Your Rights  

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 personalised advertising when you use the services.

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 

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Service to you. As a Macau 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 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 requester to ensure that he/she is the person legally entitled to make the data access request. 

 

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request. 

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However, this may affect our provision of the 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 specified in Section 2 (How We Process Your Personal Information) are voluntary, which may include to show you personalised recommendations or advertising. We may also use your personal data for the voluntary purpose of sending information to your email or via SMS that we may consider relevant to you.

 

In general, we do not require your consent to carry out the transfers detailed in Section 3 (How We Store and Share Your Personal Information). In any case, by using the 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, and “Advertising” as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us as specified in Section 7 (Contact).

Morocco 

We collect information for purposes strictly necessary for the proper use of the Service. By accepting this Privacy Policy, you explicitly accept that your personal data may be subject to processing by 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 as described in Section 1 (Children) above, you undertake that you have the consent of your parent or legal guardian to register an account on and use the 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, pursuant to the Personal Data Protection Law (the “Law”). You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.  

You can also withdraw your consent or demand a suspension of the personal information processing at any time.  

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection. 

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 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

Data Destruction

 

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

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

Act on the Consumer Protection in Electronic Commerce, Etc. 

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

In an electronic commerce or a mail-order sale: 

  • Records regarding labelling and advertising (6 months) 
  • Records regarding execution or withdrawal of a contract (5 years) 
  • Records regarding the payment of a price and the supply of goods and services (5 years) 
  • Records regarding customer services or dispute resolution (3 years) 

Protection of Communications Secrets Act 

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

  • Log records, IP address (3 months) 
  • The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months) 

 

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

 

Additional Use and Provision of Personal Information

 

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

 

Domestic Privacy Representative 

 

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

 

Contact 

 

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.  

 

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 clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 3 (How We Store and Share Your Personal Information).

 

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

 

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 7 (Contact).

South Africa 

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

Sri Lanka  

By clicking “accept”, you consent to the Privacy Policy and permit the collection, use and disclosure of your personal information. However, if you are under the age as described in Section 1 (Children) above, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service. 

Personalised Marketing 

By clicking “accept”, you hereby consent to being shown personalised advertisements. You may choose to stop receiving personalised advertising from us by following the opt out instructions included in the Settings section of the Service or by contacting us at Section 7 (Contact).

Taiwan 

We do not knowingly collect or solicit personal information from anyone under the age of 7 or knowingly allow such persons to register on the Service platform. If you are under 7 years of age, please do not attempt to use or register for our Service or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using the Service. In the case of users located in Taiwan, persons under the age as described in Section 1 (Children) above are required to obtain parental/guardian consent prior to using the Service. 

Thailand 

By clicking "accept", you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the Service. 

 

If you are under the age as described in Section 1 (Children) above, 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 as set out in Section 7 (Contact).

 

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in Section 7 (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 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): 

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 by in this Privacy Policy. 

United Arab Emirates  

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 the Privacy Policy, including (without limitation) for the purposes of showing you personalised advertising when you use the Service.  

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. 

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 2 (How We Process Your Personal Information).

 

We disclose each of the categories of personal information that we collect as described in Section 3 (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 as specified in Section 7 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.

 

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

 

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

 

Questions

 

If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 7 (Contact).

 

Vietnam 

By accepting this Privacy Policy, you expressly agree and authorise us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy. 

 

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.  

 

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.