PRIVACY POLICY
1. About this
Privacy Policy
Our Privacy Policy applies to any user of our games and
related services, applications and software.
We care about your privacy and we think it is important that
you always know what information we obtain about you in the context of your use
of the Sesisoft games and what that information is used for. In the Privacy
Policy below, we therefore aim to keep you fully informed as to the type,
extent and purpose of the collection, storage, use and processing of personal
data on our websites, PC games, Mobile platforms and products and/or services
relating to the Sesisoft games and related services and game support
applications and software (the "Games") and any Sesisoft website on
which this Privacy Policy is posted (the "Websites").
Personal data is all information relating to an identified
or an identifiable natural person. A person is identified when the identity of
a specific person can be deduced from the information itself. A person is
identifiable when we can make a connection to a specific person using
additional information available to us.
This Privacy Policy applies to the Games and Websites only.
You can also see this Privacy Policy at the websites.
We recommend that you read the privacy policy of every
other service provider you make use of, in particular before you make your
personal data available to them.
Please read this Privacy Policy carefully to understand our
practices regarding your personal data and how we will treat it.
IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT
DOWNLOAD, REGISTER WITH, OR USE OUR GAMES OR VISIT OUR WEBSITES.
By downloading our games, visiting our Websites and using
our products and services (including the Games), you acknowledge the terms of
this Privacy Policy and the use and disclosure of your personal data as set out
in this policy.
2. Who we are
We are a provider of games and related services and
applications.
We are Sesisoft Co., Ltd., located at 2Fl., 20, Bangbae-ro
22 gil, Seocho-gu, Seoul, Korea
(hereinafter: "Sesisoft" "we" or "us").
We are the provider of the Games and the Websites and the
organization responsible for the personal data you provide as part of using the
Games and the Websites within the meaning of applicable data protection and
privacy laws.
3. How to
contact us
You can contact our dedicated privacy contacts with any
queries or complaints regarding your data.
If you have any questions about this Privacy Policy or our
use of your personal data, if you need to report a problem, or if you would
like to exercise one of your rights under this Privacy Policy you can contact
us using the following contact details:
Title: Data Protection Officer
Email: privacy@sesisoft.com
4. How we get
information
We collect certain information about you when you use a
guest account.
We may collect the following types of information relating
to you indirectly through Sesisoft Co., Ltd.:
• When you log into the Games using a Guest account or
third party social media platforms such as Facebook, Google or Twitter, Apple,
Google Play Games, Apple Game Center
• Membership number
• Nickname or Name
• Connection record (connection IP, country/language/time
zone/offset of subscription, login dates)
• Service use record
• Device information (device ID, country of settings,
language of settings, model name, OS, OS version, whether routed, ADID); and
age
When you pay for the use of the Games we receive your
payment records (payment amount, name of product, payment date, order number).
During your participation and progression in our Events, we
may also collect certain personal data about you, such as name, email address,
cellphone number, address for the prize delivery etc.
When you pre-register for the game, we may collect your
country information mobile number or email address. If you 'check My PC Specs',
we will collect your PC Specs information. Your PC spec information, that is
collected, will not be used for any other purpose than game running, game
installation and game-related trouble-shooting.
We log your visits and use of our Games using cookie
technology
We also collect the following information automatically
when you play the Games or visit the Websites:
• Connection record
(Connection IP, IP address, country/language/time
zone/offset of subscription, login dates, detection and blocking history)
• Service use record; and
• Device information
(Device ID, Android ID, country of settings, language of
settings, model name, OS, OS version, whether routed, ADID, UUID).
To do this we may use cookies or mobile cookies (pieces of
data sent by a website to your computer and stored on its hard drive or a small
file placed on your smartphone). We also use analytics, indicator and tracking
analysis tools in our games that utilize cookies and similar mechanisms. See
below for more information about how we use cookies.
Where processing is necessary for us to carry out our legal
obligations
We have legal obligations that we need to comply with, and
we are allowed to collect your personal data when we need to comply with those
legal obligations.
IF YOU DO NOT WANT US TO COLLECT ANY OF THE INFORMATION
DESCRIBED IN THIS link, DO NOT USE OUR WEBSITES, DOWNLOAD OUR GAMES OR DELETE
THEM FROM YOUR DEVICE.
5. Linking to
third party websites
Other websites and applications may use your data
differently and have their own privacy policies. You should always read those
policies.
Within the Games, you may be provided with the option to
link through to other websites or gaming communities. These other domains, apps
and websites are subject to their own privacy practices and we encourage you to
read the privacy policies of each and every website and application with which
you interact. You visit these other websites or applications at your own risk.
You should be aware that personal data that you voluntarily
include and transmit online in a publicly accessible blog, chat room, social
media platform or otherwise online or that you share in an open forum may be
viewed and used by others without any restrictions. We are unable to control
such uses of your data and by using such services, you assume the risk that the
personal data you provide may be viewed and used by third parties for any
number of purposes.
6. Why we
collect, process and use your information
We use your data to provide you with our Games.
We collect, process and use your personal data for the
following purposes:
To provide services and comply with the service contract
• For the purposes of providing and organizing game
services and game events
• For the purposes of analyzing and tracking game data
• Settling fees, provide contents, purchase and fee
payments, delivery of goods (prizes from events, etc.)
To manage our members
• For customers services purposes
to distinguish between the members using the member
service, to prevent unlawful and unauthorized use by rogue members, to check if
they want to join, to deal with civil complaints including resolving
dissatisfaction and customer advice, to preserve records for any disputes
mediation and to give notifications
We use your data to help deal with complaints.
To manage our guests
• To deal with civil complaints including resolving dissatisfaction
arising from service use and customer advice
We use your data to provide you with details of our new
products and services.
For marketing and promotion purposes
• for specialization or development of new services
(products), to deliver promotional information such as events and to provide
services based on demographic information, statistics related to access
frequency and the members' use of the service
7. How long we
keep your information for
We don't keep your data forever.
We will not keep your personal data for longer than the
term that is necessary for the purposes for which we collect it unless we
believe that the law or
other regulation requires us to preserve it (for example,
because of a request by a tax authority or in connection with any anticipated
litigation)
When it is no longer necessary to retain your data, we will
delete the personal data that we hold about you from our systems.
After a request to unsubscribe, we may immediately delete
or store your personal data for a maximum of 30 days depending on the
individual operational policy of the Game you play, after a request to
unsubscribe for the purposes resolving unwanted customer complaints or
disputes, etc., such as unwanted deregistration, etc. caused by personal data piracy,
etc.
If you agree to receive marketing emails, you may withdraw
your consent to receive marketing email messages from us by following the
unsubscribe instructions provided in our emails. Your email address will be
stored until you withdraw your consent.
8. Your rights
You have a number of rights regarding your data. These may
vary depending on your location.
You have various rights in relation to the data which we
hold about you. To get in touch with us about any of your rights under
applicable data protection laws, please use the contact details set out above.
We will seek to deal with your request without undue delay, and in any event
within any time limits provided for in applicable data protection law (subject
to any extensions to which we are lawfully entitled). Please note that we may
keep a record of your communications to help us resolve any issues which you
raise.
9. Sharing your
information
We may need to share your data with limited third parties
(e.g. to help us provide the Games).
In general, your data is processed exclusively by us and we
do not pass on any personal user data to third parties unless we need to do so
in order to offer you certain Games services. Where we do share your personal
data, we do so with the following categories of recipients:
Service Providers
In order to provide the Games services we work with service
providers (e.g. payment service providers, platform providers, Solution
providers, Customer Support service providers and survey providers) who may, in
the course of providing the respective services, receive and process personal
data on our instruction and on the basis of a commissioned data processing
agreement. In addition, we use certain software tools, including in relation to
anti-cheat and fraud prevention analytics, which may allow the software
provider to collect certain information for the purposes of providing the
relevant services.
Regulatory bodies
We may disclose your personal data:
• to data protection regulatory authorities;
• in response to an enquiry from a government agency; and
• to other regulatory authorities with jurisdiction over
our activities.
Professional advisors and Auditors
We may disclose your personal data to professional advisors
(such as legal advisors and accountants) or auditors for the purpose of
providing professional services to us.
Replacement providers
In the event that we sell or buy any business assets, we
may disclose your personal data to the prospective seller or buyer of such
business or assets. If Sesisoft or substantially all of its assets are acquired
by a third party, personal data held by us about our clients will be one of the
transferred assets.
Indicator and tracking analysis tools
We share your personal data with certain entities which
provide us with indicator and tracking analysis tools in the Games. Other companies that place advertising
on our Games or websites may collect information about you when you view or
click on advertisements In particular, we share your personal data with:
• Google: We use Google Analytics and AdMob. For details of
how Google uses your data, please visit
https://policies.google.com/technologies/partner-sites?hl=en&gl=en;and
• Appsflyer: We use Appsflyer's analytics platform. For
details of how Singular uses your data, please visit
https://www.appsflyer.com/legal/privacy-policy
• AppLovin: We use AppLovin Advertising Services. For
details of how AppLovin uses your data, please visit
https://www.applovin.com/privacy
Please see the "Cookies" link, below for further
information on the cookies which are used as part of the indicator and tracking
analysis tools in the Games.
At your option
In certain circumstances, you have the option of sharing
information with others yourself as part of the Games (e.g. if you give out personal
data in a publicly accessible player or forum profile). However, we do not
transfer such data to other third parties.
For example, within the Games and the Websites, you may be
provided with the option to link through to other websites or gaming communities.
These other domains, apps and websites are subject to their own privacy
practices and we encourage you to read the privacy policies of each and every
website and application with which you interact. You visit these other websites
or applications at your own risk.
You should be aware that personal data that you voluntarily
include and transmit online in a publicly accessible blog, chat room, social
media platform or otherwise online or that you share in an open forum may be
viewed and used by others without any restrictions. We are unable to control
such uses of your data and by using such services, you assume the risk that the
personal data you provide may be viewed and used by third parties for any
number of purposes.
Otherwise, your data will only be passed on in special
exceptional cases, where we are obligated or entitled to do so by statute or
upon binding order from a public authority.
10. Changes to
this Privacy Policy
Changes to this Privacy Policy apply to your use of our
Games after the ¡°effective date.¡±
We will review this Privacy Policy periodically, and
reserve the right to modify and update it at any time. You acknowledge that we
may make changes to this Privacy Policy and it is your responsibility to check
back to this page from time to time to review the Privacy Policy. Provided,
however, that if such changes are significant and it is
required by applicable laws, we will endeavor to post notice or acquire your
consent
regarding such significant changes to this Privacy Policy.
Changes to this Privacy Policy will come into effect immediately upon such
changes being uploaded in the Games or to our Websites.
11. Children's
privacy
The Games are only intended for persons: (i) in Europe aged 16 or older,(ii) in
U.S aged 13 or older; or (iii) reached applicable age elsewhere
The Games are primarily intended for persons: (i) in Europe
aged 16 or older; or (ii) in U.S aged 13 or older, or (iii) outside of Europe
and
U.S, reached applicable age otherwise defined in your
country of residence ("applicable age")or older than such applicable
age.
We therefore do not knowingly collect any personal data
from: (i) children under 16 in Europe; or (ii) children under 13 in U.S or
(iii) under applicable age. Any person who provides their personal data to us
through the Games represents that he or she is of an applicable age. If we
learn that personal data of persons under these age restrictions has been
collected, then we will take the appropriate steps to delete this information.
If you are a parent or legal guardian and discover that
your child under these age restrictions has obtained an account with us or
otherwise has provided personal data to us, you may contact us using the
contact details set out above and request that we delete your child's personal
data and account.
12. Your
California privacy rights and "Do Not Track"
If you are located in California, you have certain
additional rights.
California Civil Code link 1798.83 permits users who are California
residents to request certain information identifying any third party to whom
Sesisoft may have disclosed, within the past year, personal data pertaining to
such user and such user's family for that third party's direct marketing
purposes, as well as a description of the personal data disclosed. To request
such information, you may contact us using the contact details set out above.
Any written inquiry must include "California Privacy Rights Request"
in the first line of the description. Please note that we are only required to
respond to one request per user each year.
If the California Consumer Privacy Act(CCPA) applies to
your information, you can exercise your rights to receive information about our
data practices, as well as to request access to and deletion of your
information. See the 'Your rights¡¯ section above for more information.
In addition, California residents under the age of 18 who
are registered users of any of online sites, services or applications where
this Privacy Policy is posted may under California law request and obtain
removal of content or information they have publicly posted. To make such a
request, you may contact us using the contact details set out above. Your
request should include a detailed description of the specific content or
information to be removed. Please be aware that your request does not guarantee
complete or comprehensive removal of content or information posted online and
that the law may not permit or require removal in certain circumstances.
California law permits our users who are California
residents to be informed as to how we respond to web browser "Do Not
Track" settings. We do not respond to "Do Not Track" settings at
this time, whether that signal is received on a computer or on a mobile device.
13. Cookies
We use cookie technology to provide a personalized service
to you.
We use cookies (access data files) which save the user's
personal information in order to provide a specialized service that is
customized and personalized to our users, as well as for analytics and tracking
purposes. Cookies are small pieces of data (text files) that are sent by the
website server to the user's browser or app and saved on the user's computer
and other devices. With respect to its operation, our cookies distinguish
between the users' computer or mobile phones but do not differentiate the
individual users.
You have a right to choose whether the cookies are
installed or not. You may choose to 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 refuse all cookies, you cannot use
our services that use cookies.
14. Security
We take security seriously and put in place measures to
protect your information
We have in place appropriate technical and organizational
security measures to protect your personal data, including:
• In order to protect the unauthorized disclosure of users'
personal data from hacking or any external break-ins, we currently use an
equipment that blocks any external break-ins, which protects the data from any
hacking, attacks, or unauthorized access, and we also use encryption, etc., so
that personal data may be transferred safely. In particular, the server
containing users' personal data is managed separately so that is not directly
linked to the external internet line.
• In preparation for any unexpected emergencies, we have a
policy to back-up the system and data. We are taking protective measures to try
and minimize damages caused by computer viruses by using vaccines that are
regularly updated. Only the minimum number of people have right of access to
the users' personal data. We regularly train our staff who handle personal data
on new security technology and personal data protection obligations. Further,
through an internal designated personal data protection unit, etc., we try and
correct any errors immediately upon detection by checking the company's
personal data processing procedure implementation and the relevant personnel's
compliance with the personal data protection policies.
15. Where your
information is transferred and stored
We may store, transfer and use your data outside your
country.
In general, your data will be stored in Japan, where our
servers is located.
In the event that we transfer your personal data to another
country and where the country or territory in question does not maintain
adequate data protection standards, we will take all reasonable steps to ensure
that any such transfers is undertaken in accordance with applicable data
protection and privacy laws and that your data is treated securely and in
accordance with this Privacy Policy. However, please note that where personal
data is stored in another country, it may be accessible to law enforcement
agencies in accordance with domestic laws.
This privacy policy takes effect from
April. 17, 2023