Gravity Game Vision Limited
Effective Date: June, 1, 2022
PLEASE NOTICE THAT COMPANY DO NOT PROVIDE ANY GAME SERVICE TO USER(S) IN THE TERRITORY OF EUROPEAN ECONOMIC AREA (EEA) WHICH INCLUDES THE EUROPEAN UNION MEMBER STATES AND ICELAND, LIECHTENSTEIN AND NORWAY (EUROPEAN USER). THEREFORE, PLEASE DO NOT ATTEMPT TO PLAY ANY GAME ON OR THROUGH ANY COMPANY'S SERVICES IF YOU ARE A EUROPEAN USER.
Collecting Personal Information
Our primary goal in collecting the information described below is to provide you, the user, EXCLUDING a European User, with a customized experience on our Service and to deliver better service, products, and more relevant content to our customers, prospective customers, and visitors.
1. Personal Information We Collect
Information Collected Directly From You
From time to time we may expand or change the information requested upon registration or log-in, so this may not be a complete list. We ask that you provide only your own personal information, not personal information concerning anyone else.
Usage Information. We collect details of your use of our Services and the resources that you access. Such usage information includes information about how and when you access or use our Services (such as Games accessed, game score, pages visited, purchase and use of Virtual Money and/or Virtual Goods, the details of your purchases, and your game play).
Interaction and Communications among Users. We collect information about (i) your interaction with other users (for example, invite, gift, sharing of your rank or level, screen-shots, etc.) and (ii) your communication and interaction with your contacts through social media channels (including, social network services, messengers, and any other services which has social features like invite friends and sharing information with friends).
Information through Mobile Devices. When, if any, you use an Applications or Third Party Mobile Applications on your mobile telephone or other mobile devices ('Mobile Device'), in addition to such information described above, you are authorizing us to collect, store and use/share the following information (as applicable): (i) Mobile Device type; (ii) mobile carrier; (iii) Internet Protocol address; (iv) geographic location/country; (v) platform version; (vi) navigation, interaction and engagement information regarding our users (vii) MAC address, International Mobile Equipment Identity (IMEI), display resolution, time and date on screen of Mobile Devices (viii) O.S. information, and; (ix) such other information you choose to provide to us. In addition, we receive and store information you provide when you sign up to have Short Message Service ('SMS') notifications set directly to your Mobile Device.
Payment and Billing Information. If you purchase any in-Service items, our third party partners will collect the payment and billing information necessary to complete the transaction. Such information may include: (i) your first and last name; (ii) your valid e-mail address; (iii) credit card, PayPal and other third party payment processor information; (iv) billing address; and (v) such other information you choose to provide. Our third party partner may also receive the foregoing information that you provide when you purchase Applications and Third Party Mobile Applications through your Mobile Device.
Customer Service and Support. When you send email or other communications to us in connection with customer service and support, we will collect and store your contact information, information about your use of the Service, your user ID and such other information you provide to us in order to process your inquiries, respond to your requests and improve our Service. We will also store the correspondence and any information contained therein.
Profile Information. We provide areas on our Service where you can post information about yourself and others and communicate with others or upload content such as photographs. Such postings are governed by the applicable Terms of Service. In addition, such postings may appear on other websites or services, or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable areas, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control anyone who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.
Information Received from SNS and APIs
Because the Applications is accesible through the Markets, you allow us to access certain information from your profile through the Markets' Applications Programming Interface ('API'). The information we receive varies by the Applications and by the privacy settings for the Markets and may include any or all of the following information, as allowed by you, the Markets and your privacy preferences: (i) your first and last name; (ii) your profile picture or its URL; (iii) your user ID number; which is linked to publicly available information such as name and profile photo; (iv) the user ID numbers for your friends that are also connected to our Applications(s); (v) login e-mail you provided to the Markets when you registered; (vi) your physical location and that of your access device(s) and (vii) your gender.
2. How We Collect Personal Information
Automated Information Collection Technologies
As described below, when you access our Services, we collect certain technical information and may associate such information with your user or account ID number for our internal use.
We may also use local shared objects known as 'flash cookies', which help us to prevent fraud, remember your in-game settings and to track your progress on certain in-game tasks.
You have choices with respect to cookies. By modifying your browser preferences, you have the option to reject all cookies, or limit the type of cookies you allow. Flash cookies operate differently from browser cookies and cookie management tools available in a web browser will not remove flash cookies. To learn more about and manage flash cookies you can visit www.adobe.com. Rejecting or limiting the type of cookies may, however, in limited instances prevent you from accessing certain features on our Service.
Like most Internet services, we may also use log files on the server side. The data held in log files includes your computer's or Mobile Device's IP (Internet Protocol) address, browser type, browser language, e-mail Applications, Internet service provider, referring/exit Web pages, computer platform type, date/time stamp, and user activity. The company uses server log data to analyze trends, administer the services offered through our Service. We and our third party partners may use this information for product and service improvements, and in marketing and advertising services.
The software enabling our Services has associated log and temporary files that are stored on Company's servers. These files store your account information, preference settings, system notifications as well as other data necessary to enable you to participate in our Service. Your information may also exist within regularly performed server backups.
Our Services may utilize a variety of methods for tracking purposes, including web beacons (also known as Internet tags, pixel tags and clear GIFs). Web beacons are small pieces of data that are embedded in images on the pages of websites to analyze the traffic patterns, such as the frequency users visit various areas of our Services. Pixel tags may allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation. These methods may involve transmitting information either directly to us or to another entity authorized by us to collect information on our behalf. We also use these technical methods in HTML e-mails that we send our guests to determine whether our guests have opened those e-mails or clicked on links in those e-mails. With web beacon technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address.
Third Party Advertisers
Click Through URLs
Some of our Services, including email messages, use 'click-through URLs' linked to other content on our Services. We track this click-through data to help us determine interest in topics and use of the Services.
You may also choose to disclose personal information in our Forums. Personal information you disclose in such Forums is public information, and there is no expectation of privacy or confidentiality. Please refer to the Terms of Service for additional information relating to the disclosure of personal information in such Forums.
We may collect or receive information from other sources including other users of the Service and third party information providers and partners. For example, we receive and store the information you provide when you enter any promotion, sweepstakes or loyalty program. Such information may be used to supplement your account information and/or profile and may be combined with other information we collect from you.
Use, Disclosure and Transfer
Use by Company
We use the information you provide so that we may better understand your needs and the needs of our customers, prospective customers, and visitors. Specifically, we use your personal information for many purposes, including:
- to allow you to register for and use our Services;
- to apply for employment opportunities at the Company;
- to audit and analyze data to improve and ensure the continued smooth operation of our Service;
- for market research purposes, including, without limitation, to analyze user characteristics and usage patterns in order to understand better how our Services are used and market them more effectively;
- to communicate with you concerning your account or to send you announcements, newsletters, promotional materials and other information about our Services or offerings of our business partners, and to offer you opportunities to participate in surveys, contest and sweepstakes;*
- to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving our Service;
- to respond to inquiries, troubleshoot problems, investigate incidents, and handle complaints;
- provide, maintain, protect and improve our Services, including keeping you posted on our latest Service announcements, software updates and upcoming events, and develop new services;
- protect our rights or property or that of our users;
- to satisfy any applicable law, regulation, legal process or enforceable government request;
- to enable user-to-user communications; and
- protect against harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.
The Company processes personal information on our databases, equipment and servers (owned by the Company and/or third parties in Hong Kong and in other countries). In some cases, we may process personal information outside of your country.
*If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or follow the process described in the 'Opt-Out Provision' section below
Disclosure and Transfer to Third Parties
We generally do not disclose or transfer any personal information about our customers, prospects, or visitors to any third parties. However, in order to provide other data or services to you, we may disclose and transfer the relevant data to (i) our mother company Gravity Co, Ltd., its subsidiaries, licensees and consignees, and (ii) our licensors, licensees, consignors and consignees to collect process, preserve, transmit, international transport, and exploit the data within a reasonable scope of use. Further, we maydisclose and transfer data which does not contain or reveal any personally identifiable information or is specifically attributable to you to our business partners, third party analytics service providers, and networks and advertisers (collectively, 'Partners'). Provided, however, some Partners may also act as third party service providers (described below) to us and may have access to your personally identifiable information. Moreover, Partners may obtain public information about you from your profile or other public sources.
We may also periodically engage in co-marketing activities, where we work with a complementary solution provider to launch a joint marketing program. In these situations, we will only send information to you on behalf of the other; we do not provide your personally identifiable information to such partner. We may also enter into business partnerships with other parties to provide specific services. If a user signs up for these services or responds to a particular marketing offer, we may share personally identifiable information such as your name or other contact information that is necessary for our business partner to provide these services or get in contact with you.
Disclosure of your personally identifiable information may occur when we engage or employ service providers, vendors or other third parties to facilitate the provision of our Services (including, without limitation, payment processing, data analysis, e-mail delivery, hosting services, customer service and promotional services) to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Such third party service provider ( 'Third Party Partner') may have access to your personally identifiable information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Currently, the name of Third Party Partner, services performed by it on our behalf, service territory of it, and period of retention and use by it of Personal Information are as follows:
|Name||GRAVITY COMMUNICATIONS Co., LTD|
|period of retention and use of Personal Information||5 years|
Safety, Security and Legally Required Disclosures
Your personally identifiable information, and communications you make within the Service, may be accessed and disclosed if we believe that our Service is being used in the commission of a crime, when we believe in good faith that there is an emergency that poses a threat to the safety of you or another person and when necessary either to protect our rights or property including to enforce our Terms of Service, or for us to render the service you have requested.
We may also disclose personally identifiable information when required by law, regulation, court order, or in response to a subpoena or litigation discovery request, or in the good faith belief that such action is necessary in order to conform to the edicts of the law or comply with a legal process served on us. In addition, we will make any legally required disclosures to government authorities and provide notice to you of any breach of security, confidentiality or unauthorized release of personal or private data in accordance with applicable laws, rules and regulations.
Storage and Security
We employ reasonable measures (both online and offline) to protect the security of information we collect from you. Such information is housed in secure databases, equipment and servers located in Hong Kong and/or in other countries. The databases, equipment and servers we utilize may be owned by third party providers. To prevent unauthorized access, loss, or misuse, maintain data accuracy, and ensure the appropriate use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we maintain. We use industry-standard technology, such as firewalls, in an effort to protect the confidentiality of your personal information. Moreover, in addition to password protection offered in connection with your Service account, we encrypt your transmission of sensitive information to us (e.g., account passwords and payment-related identifiable information) via SSL (secured socket layer) protocol in the interest of heightened privacy protection and information integrity.
Although we take reasonable precautions against possible security breaches of our Service, databases, equipment or servers, and records, we cannot guarantee that unauthorized access, hacking, data loss, or other security breaches and factors beyond our control will never take place and result in disclosure of your personal information. Accordingly, we disclaim any guarantees, warranties or representations relating to maintenance or nondisclosure of any personal information collected from you. We strongly urge you to take reasonable measures at all times (online and offline) to protect your personal information, including your password and other sensitive information.
In addition, while we strive to protect your personal information, you should know that information sent over the Internet, whether by e-mail or by using one of our on-line forms, is not necessarily secure against interception. Therefore, we cannot be responsible for such interception and cannot guarantee the security of such information.
Review, Update, Correct, or Delete Personal Information
Generally, you may review, update, correct or delete your personal information collected by or through our Service by logging into your account. You may also correct factual inaccuracies. Certain types of personal information that is necessary to check eligibility, such as birth date or age, cannot be deleted, but may be modified with sufficient verification of the new information. Note that we reserve the right to terminate or delete any registration or promotional entry if we believe the personal information submitted was knowingly false or fraudulent.
To delete your personal information, you may also contact us by accessing the customer service center system installed on our service webpage named 'Gnjoy.hk.'
We will use commercially reasonable efforts to honor your request.
Please be aware that even after your account is terminated or deleted, some or all of your information may still remain visible to others, including but not limited to any information that has been: (i) incorporated into others user's content, comments, postings, submissions, cities, resources or other in-game assets; (ii) copied, stored or disseminated by other users; (iii) shared or disseminated by you or others such as in a public posting; or (iv) posted on a third party platform. A request to delete and/or termination of your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us. We are not able and/or obligated to remove any of your information from a third party platform.
To have access to your personal information, you must provide proof of identification such as full name, street address, city/state and zip code, user ID and password, and/or information about your recent activity on our Service. We reserve the right to deny access to any user if we believe there is a question about your identity. And if the burden or expense of providing access to your personal information is disproportionate to the risks to your privacy, or if the legitimate rights of others would be violated, we may decide not to provide access to such information. Moreover, we may still retain an archived copy of your information in our files as required by law or for legitimate business purposes, including, resolving disputes, enforcing the Terms of Service, and for other technical and legal requirements and constraints related to our Service.
To manage the information we receive about you from the SNS where you play our games, you will need to follow the instructions at that SNS for updating your information and changing your privacy settings.
Notification of Changes
Links to Third Party Websites, Services and Offers.
Our Service may contain links to other websites, services and/or offers from third parties. We are not responsible for, nor will it be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information you voluntarily chose to provide to them. You should review the applicable privacy policies and information practices of such third parties carefully before providing personal information to them. Moreover, if you have any questions or concerns, you should contact the third party directly.
Protection of Children's Privacy
Children who reach the age ('Competent Age') to give valid consent under his/her relevant national law or who do not reach the Competent Age but get valid consent from their legal representative (e.g. parents) can only use the Applications. Therefore, the children under the Competent Age have already obtained the consent of the legal representative to continue to enjoy our Services. If children under Competent Age or their legal representative ask us to cease processing or profiling of the child's Personal Data for the purposes of direct marketing, we will immediately do so.
Special Note to Parents
If you become aware that your child has provided us with personal information at our Service, we invite you to notify us so that we may delete the information from our records and discontinue any related features or services (see Opt-Out Provision above). We also urge parents to instruct their children never to give out their real names, addresses or phone numbers without parental permission when using the Internet. We appreciate your cooperation in assisting us to provide a safe and enjoyable online experience for your children.
Retaining and Deleting Personal Data
We retain your Personal Data only for the period of time necessary to achieve the particular purpose for which the information was processed. Typically, without your request to erase Personal Data and also without legitimate reason to keep it longer, after the termination of our relationship, we retain your information for 5 years after the deregistration of your Game Account. We may delete your Personal Data where you have not logged in to our Services for more than 1 year. Further, we may also erase your Personal Data if we are necessary for the smooth maintenance of our Service.
Users Outside Hong Kong
Users in certain jurisdictions may have a right to access his/her personal information held by the Company and/or its Affiliates. Your right of access to such personal information can be exercised in accordance with applicable laws, rules and regulations.
Please submit any requests for such access to the customer service center system installed on our service webpage named 'Gnjoy.hk.'
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