BILIBILI GAME Privacy Policy

Date Last Updated: [2024-08-23]

The privacy policy You are reading ("Privacy Policy") is a legal agreement between You and BILIBILI HK LIMITED ("bilibili" or "We" depending on the context) concerning your use of the bilibili gaming platform and its services (hereinafter referred to as "the Platform") we provide. The foregoing services include, but are not limited to, the games that we operate and other game-related online services that we make available to you on the Platform.

We recognize and highly value the privacy of our users (hereinafter referred to as "You" or the "Users"). This Privacy Policy outlines the purposes, methods, and scope of our collection, storage, processing, sharing, transfer, and use of your personal information, as well as your rights and choices regarding the personal information You provide or that we collect in connection with the Platform. By visiting our website or using the Platform, You acknowledge that You have read, understood, and accepted the following terms. If You do not agree with the terms, some essential features of the Platform may not function properly, which may prevent You from using those features.

This Privacy Policy applies to personal information that You have provided to us and that we have collected from You through your use of the Platform. It is important to read these policies carefully before using any specific game services or third-party services to understand how your personal information is collected and processed. Unless otherwise provided, the privacy policies of standalone games and/or third-party services shall govern the collection and processing of your personal information when using such game recharging services or third-party services through the Platform.

The services and features of the Platform may be updated occasionally due to legal, technical, or business changes. We reserve the right to revise or update this Privacy Policy at our discretion, and any such amendments will constitute a part of this Privacy Policy. We encourage You to regularly review the latest version of this Privacy Policy to stay informed about your rights. We will notify You of any updates to this Privacy Policy by updating the date at the top of this Privacy Policy. Please ensure You read the revised terms carefully. Please refrain from providing us with information (when requested) and cease using the Platform immediately if You do not agree with any revisions to this Privacy Policy. Continuing to log in or use the Platform after the amended terms become effective shall be deemed as your acknowledgment and acceptance of the amended terms.

Summary

The following is a summary of this Privacy Policy.

Contents

Section 1 Data We Collect and Process

Section 2 Why We Collect and Process Your Personal Information

Section 3 Provision of Your Personal Information

Section 4 Cookies or Similar Technologies

Section 5 Cross-border Data Transfers

Section 6 Data Retention

Section 7 Your Rights

Section 8 Protecting User Data Security

Section 9 Age Restriction and Children Protection

Section 10 Contacts and Complaints

Section 1.       Data We Collect and Process

The data we collect and process from You can be categorized into the following:

(1)   Data You directly provide to us

i.               Account Data

Some of the services provided via this Platform require You to log in to our system. Therefore, we will collect your account data including your email address (if You choose to use Our services by email), phone number (if You choose to use Our services by phone number), password, username, nickname, and profile picture. We will use such information to create an account for You to log in and use our services.

ii.              Customer Support Services

When You use our customer support services, we may collect the information You provide, such as purchase details (including purchase time, products, currency, and fees), UID, device information, username, app name, app version, app package name, chat data, and game data, as needed for customer service. This information assists us in identifying your account for troubleshooting account or game issues, communicating with You, and addressing your questions or requests to facilitate the performance of our contract with You.

iii.            Other Data You Provide to Us

•   Data You provide to us when participating in online discussions or interacting with us in other ways;

•   Data You provide when You post on our message boards, complete a customer survey, or submit feedback/requests via email;

•   We also collect any data for any content You choose to share via this Platform;

•   If You get the prize(s) for participating in Our game-based events, We may collect your name, delivery address, postcode, phone number, gaming account ID, and game regional server ID in order to send physical prizes to You, and your email address will be collected to send You any digital prizes won. We collect such data with your consent.

(2)   Data We Proactively Collect

We may also proactively collect your data through technologies when You use the Platform. In addition to providing You with the services and features related to this Platform, we may also use this information to modify or improve features, manage our systems, address technical issues, prevent fraud, and for data analysis. This information is necessary for us to provide You with our services and to ensure service security.

i.               Login Information

We will collect your internet protocol (IP) address and device language, along with your country or region, to connect to regional servers and allow You to use the services available in your country or region. We may also use your IP address to help resolve account disputes.

ii.              Transaction Information

We will collect your IP address, device language, order number, payment method, amount, currency, product ID, quantity, order creation and completion time, purchase time, transaction completion time, username, character ID, and character name when You use the game recharging service provided via this Platform to assist You in completing your transaction. This Platform uses third-party payment services to facilitate seamless transactions. We will not collect payment account details, but we will disclose your order number and transaction amount information to third-party payment service providers to help You complete your payment.

iii.            Device Data

When You use some services of the Platform, We will collect your gaming data, such as the app package name, app version, server ID, device memory, available memory, device model, device storage, available storage, OS Version, network type, region, and service provider to provide services and address any issues You may encounter.

(3)   Data We Collect From Third Parties

i.               Linked social media account information

Most of our services support signing in with social media accounts (such as Google or Apple accounts). We may collect personal information shared by the third-party social media account that You authorize when You log in to the Platform through that third-party social media account.

Depending on your privacy and authorization settings on the third-party social media platform, we will collect the following information:

•   Google: We will collect your authorization ID, nickname, profile picture, and email address, and confirm if the email address is verified by Google.

•   Apple: We will collect your authorization ID, nickname, profile picture, and email address, and confirm if the email address is verified by Apple.

This data helps You link, connect, or log in to your account via third-party social media accounts. Our legal basis for processing this data is to provide services to You. The information we receive from third-party social media platforms is based on your privacy settings on such platforms. You should regularly check and adjust your privacy settings on third-party social media platforms, if necessary, before logging in and using our services via any social media account.

ii.              Other Information from Third Parties

We may occasionally collect your personal information from other third parties. For instance, if You access our services by clicking an advertisement, We may receive the information that allows Us to know which ad network and advertising campaign your installation originated from.

(4)   Special Instructions

When you successfully register an account on the Platform, you can use the account to conveniently log in and use all the game services under the Platform without having to register a separate account in order to use a particular game service.

Section 2.       Why We Collect and Process Your Personal Information

i.               We will collect and process your personal information based on the following principles:

•   The principle of minimum and necessary;

•   Specific, clear, and legal purposes;

•   Adequate, relevant, and solely limited to what is necessary to achieve the purposes;

•   The manner that ensures appropriate security of the personal information.

ii.              We collect and process your personal information on lawful grounds permitted by law, which may include, in accordance with applicable data protection legislation:

•   Your consent to our collection and processing of your personal information;

•   Entering into user agreements with You and/or performing the obligations under such agreements to provide our services;

•   Our legal rights or those of third parties;

•   Your legal rights or those of third parties; or

•   Other legal reasons include compliance with legal, governmental, or regulatory agency requirements, or processing your personal information for the public interest.

iii.             We collect and process your personal information to:

•   Allow You to access and use, or restrict your access and use of our services;

•   Analyze and manage our services with respect to system administration, user services, membership activities, security, fraud detection, account owner verification, and archiving and/or backup purposes;

•   Fix software bugs or errors, improve our services, and respond to customer needs and preferences, including language and location personalization, personalized support and instructions, and other responses;

•   Develop new services or products as requested by users to enhance user experience;

•   Verify and complete payments;

•   Deliver advertisements, recommendations, and marketing information You may be interested in (You may contact us to turn off this feature);

•   Communicate with other users to resolve their requests or issues;

•   Perform our user agreement with You and act against violations of the user agreement;

•   Provide You with personalized experiences such as personalized displays and push notifications;

•   Send You notifications and prompt updates about the latest products, provide software verification, update, and management-related notices, notify You about new special events, notify You to participate in surveys or activities we organize, and provide You with other information about our services;

•   Protect the integrity and safety of our services and users, perform legal obligations, and comply with the game user agreement and/or other restrictions during your use of our services;

•   Investigate, claim, or take legal action against policy or procedure violations pursuant to applicable laws and legal proceedings;

•   Comply with applicable laws, legal proceedings, industry standards, and our company policies; or

•   prevent, investigate, or identify potential or actual fraudulent or illegal conduct or any other kind of conduct that violates our policies, or take other relevant actions.

Section 3.       Provision of Your Personal Information

(1)   We do not usually share personal information that directly identifies You with unaffiliated third parties, unless:

i.               With your prior consent or authorization;

ii.              To comply with the law, legal proceedings, or requirements of law enforcement or government agencies;

iii.             When disclosure is necessary or appropriate to prevent personal injury or financial losses, or when investigating suspected or actual illegal conduct;

iv.             When the disclosure is necessary to protect our interests or those of our users (such as to prevent death, personal injury, or serious property damage), as well as public safety and the public interest; Or

v.              In the event of a sale of part or all of our assets, we may disclose your data to third-party buyers. In such cases, the buyers shall comply with this privacy policy and applicable laws.

(2)   Notwithstanding the foregoing, You agree that we may share your personal information with other parties for the following purposes. You acknowledge that You foresee and agree to such disclosure when providing your personal information. We will take various precautions to protect your personal information when sharing your information with others, including without limitation (i) informing You in advance of the purpose, type, and recipient of the disclosure and obtaining your consent and authorization when necessary; (ii) using agreements to make sure the recipients fulfill personal information protection obligations and assume legal liability; (iii) having our security team will assess and optimize the precautions taken for information transfer and anonymize personal information to the greatest extent possible; (iv) complying with applicable laws and ensure information transfers comply with local data protection laws when transferring your information to other countries/regions, regardless of whether to our affiliates or third-party partners.

i.               Jurisdictional Agencies. We may provide some or all of your personal information to judicial or administrative agencies upon your request, as required by law, or to comply with applicable law or jurisdictional agency requirements. In addition, we may disclose some of your personal information within a strictly limited scope if deemed necessary to protect our legal rights or those of our users or other third parties or to protect the public interest.

ii.              Our Affiliate Group Companies. We may share your information with our affiliate companies, including our parent company, subsidiaries, and sister companies. Specifically, we may share your information with subsidiaries that provide services such as customer support, marketing, or technical operations on our behalf. Our subsidiaries will process any of your personal information shared with them in accordance with the requirements of this Privacy Policy.

iii.             Third Parties Acquiring All or Substantially All of Us or Our Business. We may disclose your information to third parties under the following circumstances: (a) we may disclose your information to any potential buyers, new owners of the company, or third parties involved when any part of our business is sold, assigned, merged, consolidated, reorganized, or when any part of our business is merged with other business, acquired, or involved in a joint venture; or (b) we may transfer any personal information collected to potential buyers, new owners, or other third parties involved in the transaction or assignment of any of our assets.

(3)   We may need to provide your personal information to third-party service providers to assist in delivering services to You to achieve the purposes outlined in Section 2 of this Privacy Policy. Third-party service providers we use may include:

i.               Logistics Services Providers. We may share information like your address and phone number with logistics service providers who provide transportation services, such as delivering physical prizes.

ii.              Customer Service Providers. We will use customer service providers like AIHelp to provide online support and other customer services. We will share your UID, username, app package name, app version, server ID, device RAM, available RAM, device model, device storage, available storage, OS version, network type, location, service provider, and other chat or game data needed by customer service providers to assist in resolving your queries when using our customer support services.

iii.             Cloud Service Providers. We will use cloud service providers to assist with data storage.

Additionally, we may also occasionally authorize other third-party service providers to provide services to You to improve your user experience.

When authorizing partners to process your personal information, we will reach an agreement covering the purpose, duration, methods, type of personal information, precautions, and the rights and obligations of both parties and shall oversee all partner data processing activities.

Section 4.       Cookies or Similar Technologies

We may use Cookies or similar tracking technologies to automatically collect certain information to learn more about your interests, provide you with essential features and services, and analyze trends and manage the Platform whenever You use it. When you use our Platform, approved third parties (including but not limited Google) may also set cookies and related technologies to provide you with personalized advertisements and measure advertising effectiveness. You can learn more about how those cookies work by visiting https://business.safety.google/privacy/..

Many browsers allow You to control the use of cookies at the individual browser level. Cookies are small data files stored on users' devices at the request of websites or this Platform, allowing the site or this Platform to recognize returning users and retain information such as user preferences and history. Any personally identifiable information collected through or together with data obtained through Cookies shall be treated as personal information. For instructions on blocking, clearing cookies, or enabling warnings, please refer to your browser or mobile device's instructions or help interface. It may not be possible to delete or disable cookies on certain mobile devices and/or browsers.

Please note that some functions may not perform as intended if your browser or mobile device does not support or blocks Cookies. For instance, You may not be able to log in or access certain features or services of this Platform.

Section 5.       Cross-Border Data Transfer

Data generated or collected during your use of the Platform will be stored in Japan. We have service teams and affiliates worldwide, meaning your personal information might be accessed by our support team, engineers, and/or affiliates globally, depending on the services used. Data protection laws in these countries or regions may differ from those in your country or region of residence. We will take appropriate precautions as required by applicable laws and ensure your personal information is protected pursuant to applicable laws and this privacy policy. We will also require Group affiliates, service providers, and business partners to protect your personal information when processing it and providing You with services.

Section 6.       Data Storage

We will not store your personal information for longer than is necessary to fulfill our obligations or as required or permitted by applicable laws (whichever is longer). Upon the expiration of the storage term, your personal information will be deleted, masked, or anonymized as required by applicable laws.

Upon your request for removal or deletion of your personal information, we will assess if the data is necessary for our lawful business interests, such as compliance with legal obligations, dispute resolution, and/or enforcing agreements. If so, we will retain your data until it is no longer necessary. Please note that removing or deleting your data may result in the termination of some of the services we offer.

Section 7.       Your Rights

In accordance with applicable data protection legislation, You may be entitled to different data subject rights to the personal information while You use the Platform and provide us with the personal information while we collect this information. To exercise the rights outlined in this Section, please contact us via the online customer service available on the Platform or through online customer services within specific games. We will respond within 30 days, which may be extended by up to two months under certain circumstances. Please note that we may require You to verify your identity before proceeding with your request.

(1)   Right to Know of the Collection, Disclosure, or Sale of Your Personal information

You have the right to access any personal information we have collected about You. You may be authorized to request a copy of the personal information we have collected under applicable law in certain jurisdictions. You are also entitled to obtain a copy of the data You have provided to us in a structured, commonly used, and machine-readable format. Please contact us if You wish to make such a request. We reserve the right to charge reasonable fees (based on the administrative costs incurred) or to refuse to act on a request if, in our reasonable opinion, your request infringes on the rights or freedoms of other users, or is manifestly unfounded or excessive.

(2)   Right to Correct

If We process your personal information, we shall endeavor to ensure by implementing suitable measures that your personal information is accurate and up-to-date for the purposes for which it was collected. If your personal information is inaccurate or incomplete, You have the right to request us to correct your inaccurate personal information.

(3)   Right to Request the Deletion of Personal information

You have the right to request the deletion of your personal information by submitting a verifiable request via email if the conditions described in this privacy policy no longer apply, or if You have any other valid reasons for the deletion.

You can delete your game account in most of our games by clicking [Settings] – [Delete Your Account] or by contacting us to exercise your rights. Please read the instructions on the account closure page carefully. Unless otherwise provided by laws and regulations, we will promptly delete or anonymize your personal information pursuant to applicable laws and regulations if You choose to close your account.

We may need to retain your personal information if we have a valid reason to do so under data protection laws (for instance, in defense of a legal claim or freedom of speech), and will inform You in such cases.

(4)   Right to Revoke Consent

You may withdraw any consent previously given to us for specific processing activities to the extent permitted by applicable laws and regulations. We might not be able to provide certain services that require your consent to process your personal information if You do not agree to or withdraw your consent to such processing. We may no longer continue to provide the services reliant on your consent or authorization upon withdrawal of your consent or authorization, and will no longer process your personal information for such services. However, the withdrawal of your consent or authorization will not affect any processing that occurred before the withdrawal.

(5)   Right to Refuse

You have the right to refuse our processing of certain personal information pursuant to applicable laws and regulations, such as information processed for direct marketing purposes or personal information processed for business or public interest reasons. We will stop processing your data for legal or public interest reasons if You object to our processing of your personal information for such reasons unless required to do so by law or other compelling legal reasons, or when such data is required for establishing, fulfilling, or defending against legal claims. You also have the right to file a complaint with the appropriate regulatory agencies. You may request that we stop processing your data for direct marketing purposes at any time if any of your data is being processed for such purposes.

(6)   Right to Restriction of Processing

You have the right to request restrictions on the processing of your personal information pursuant to applicable law. Particularly when:

•   You dispute the accuracy of your data;

•   The processing is unlawful, and You oppose the deletion of your data;

•   We no longer need your data for processing purposes but You require it for establishing, exercising, or defending legal claims; Or

•   You have objected to certain processing activities and are still awaiting our response.

Please contact us if You wish to make such requests.

(7)   Right to File a Complaint With a Data Protection Agency.

You may file a complaint or legal claim with the appropriate regulatory agencies in your jurisdiction if You believe we have violated any data protection laws.

Section 8.       Protecting User Data Security

Securing our users' data is a top priority for us, and we will continuously implement and update administrative, technical, and physical security, such as access controls and encryption, to protect your data against unauthorized access, loss, destruction, or alteration.

Unfortunately, no internet data transmission is completely secure. Despite our best efforts to protect your personal information, please be aware of the potential risk of hacker attacks, cyber-attacks, and risks on the internet.

We strongly recommend that You take all possible precautions to secure your personal information while using our services. This includes without limitation regularly changing your password, not using real names or other personal information when creating an account, creating a strong password with a mix of letters and numbers, using a secure web browser, and other appropriate security precautions.

In the event of any security incidents, we will notify You electronically or by posting a notice on our website so that You may take the appropriate action. We may also post a notice on our website in the event of a security breach. We will send security incident reports to the appropriate agencies and cooperate with them to mitigate further harm pursuant to applicable laws.

Section 9.       Age Restrictions and Children Protection

Children (generally those under 18, depending on your jurisdiction), are not permitted to use this Platform for any purpose unless their parents or legal guardians have given their consent (if applicable in your jurisdiction). We have provided a table below listing the minimum age requirements by region as of the date of this Privacy Policy. Always refer to the laws governing your jurisdiction to ensure compliance with minimum legal age requirements.

We do not and will not intentionally collect personal information from minors without the consent of their parents or legal guardians. Parents and guardians are strongly recommended to instruct minors not to provide personal information while using our services without their prior consent. We will promptly delete any personal information collected from minors upon learning that we have collected such data. Additionally, please contact us if You believe we may hold any personal information about minors.

We will process any email addresses requested from parents or guardians for verification purposes pursuant to applicable law. This is to inform You about such processing or changes to this Privacy Policy and to verify your data subject requests.

Section 10.    Contact and Complaints

Notwithstanding the above, certain countries, states, provinces, or jurisdictions may not allow the exclusion of certain warranties or the limitation of liability as stated above, and therefore some provisions may not apply to You. Furthermore, You may have legal rights specific to your jurisdiction, which shall not be overridden by this Policy.

If You have questions regarding this Privacy Policy or require assistance with issues related to your personal information when using our services, please contact us through the online customer services available on this Platform or the online customer services in specific games.

Additional Terms for Specific Jurisdictions

The laws of some jurisdictions may include additional requirements beyond those listed here for users of this Platform.

In addition to this Privacy Policy, the terms specific to your jurisdiction shall apply if You reside in one of the jurisdictions listed below.

California, USA

This section applies specifically to residents of California, USA, under the California Privacy Act (CPRA, previously known as the California Consumer Privacy Act (CCPA)).

Personal Information Collection and Disclosure. Over the last 12 months, we have collected and disclosed the following types of personal information from You or your devices:

•       Identifiers such as your username, open ID/user ID, nickname, IP address, device ID, operating system, device type, other device information, email address, and your social media profile.

•       Data related to the use of our services: including game data (such as game settings) and in-game interactions.

•       Commercial information about transactions completed via our services or through third parties, such as the purchased products and their prices.

•       Customer support information and security information.

•       Other information is described in Part 1.

We have not sold any California resident personal information covered by the CPRA in the past 12 months.

Rights of California Residents. California law provides California residents with specific rights and mandates the following restrictions on certain business practices.

Prohibition on the Sale and Sharing of Personal Information. California residents are entitled to choose that their personal information not be sold or shared (as defined in the CPRA). We do not sell personal information about residents who We know are younger than 16 years old.

Initial Notices. Residents of California must be informed about the types of personal information we collect and the purposes for which it will be used during or before the time personal information is collected. This Privacy Policy is made available to online users to meet this requirement.

Request for Deletion. Subject to certain exceptions, California residents have the right to request the deletion of their personal information that we have collected. They can also request that this personal information be deleted at no charge unless an exemption applies. To submit a request, please contact us through our online customer services available on the Platform or customer services in specific games. We will address your request within 30 days.

Request for Correction. Subject to certain exceptions, California residents have the right to request the correction of any of their personal information that we have collected.

Right to Know Request. Subject to certain exemptions, California residents have the right to request and receive a copy of specific personal information we have collected about them in the past 12 months. The copy will be sent via email at no charge and in a readily usable format that allows individuals to transmit this information to other entities without hindrance. To submit a request, please contact us through our online customer services available on the Platform or customer services in specific games. We will address your request within 30 days. California residents also have the right to request that we provide them with specific information about how we have processed their personal information over the past 12 months, including:

•   Types of personal information collected;

•   Type of personal information source;

•   Business Reasons for collecting or selling their personal information;

•   Categories of third parties to/with whom we disclose or share their personal information;

•   The types of personal information we disclose to or share with third parties for business purposes; and

•   Types of third parties to whom the personal information of residents is sold, and the specific types of personal information sold to each type of third party.

•   California residents may make up to two right-to-know requests per 12-month period.

We will respond to verifiable requests from California residents in compliance with the law.

Right to Non-Discrimination. The CPRA prohibits discrimination against California residents for exercising their rights under the CPRA. A business may be deemed as discriminating against California residents if it refuses to provide goods or services, provides a different level or quality of goods or services, or charges (or implicitly charges) different prices, rates, or penalties for California residents exercising their rights under the CPRA, unless such behaviors are reasonably related to the value the resident's data provides to the company.

Financial Incentives. Companies may offer financial incentives for the collection, sale, or deletion of personal information of California residents as long as such incentives are not unfair, unreasonable, coercive, or usurious and are offered in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives and their material terms, to opt out of such incentives at any time, and not to be included in such incentives without their prior informed consent. We currently do not offer any such incentives.

Retention. The duration we retain personal information is based on what is reasonably necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, prevent fraud, or enforce agreements.

Your rights under the California Shine-the-Light Law. We will not share personal information collected online with unaffiliated third parties for their direct marketing purposes unless You consent to such disclosure. If You are a California resident and believe your information has been disclosed, or if You have questions about how your information is shared, please contact us to request a list of the types of personal information disclosed to third parties for their own marketing purposes. You can make such a request once a year. Please show proof that You are a California resident and include your current California address in your request so that we can respond appropriately.

Indonesia

Consent. By accepting and agreeing to this Privacy Policy, You consent to the collection, use, and sharing of your personal information in accordance with this Privacy Policy, which may be subject to occasional changes. You may not access or use our services if You disagree with this Privacy Policy, and we reserve the right to refuse to provide You with access to our services.

Consent from Parents and Guardians

If You are under 21 years of age, You confirm that You have obtained the necessary consent from your parents or legal guardians to register for an account on this Platform and use the game services.

Data Subject Rights. Under applicable Indonesian data privacy laws, You have the right to access personal information about You that You have provided, and that we have collected and stored during your use of this Platform.

Unauthorized Data Disclosure. We will notify You via the contact details You provided or through this Platform if we fail to maintain the confidentiality of the personal information provided and collected during your use of this Platform, with the intent of minimizing the impact of such data disclosures as much as possible in compliance with local laws.

Notifications on Amendments to this Privacy Policy. You will be deemed to have accepted the amendments and agree to the revised privacy policy if You do not expressly object to any amendments to this Privacy Policy within fourteen (14) days of the revised policy being made available. However, You may close your account and suspend the use or access of our services at any time if You no longer agree with the revised privacy policy.

Data Accuracy and Third Party Consent. You are obligated to ensure that the personal information You provide is accurate and up-to-date. We reserve the right to verify the accuracy of the information You provide at any time. You confirm that You have obtained all necessary consent before providing us with personal information belonging to others (e.g., for referral promotions). We will assume such consent has been obtained, and You shall be held liable for any third-party claims arising from the absence of such consent.

Malaysia

Consent from Parents and Guardians. Please do not use our services without the permission of your parent or guardian if You are under 18 years of age.

By agreeing to this Privacy Policy to facilitate a minor's access and use of this Platform, You agree to our processing of the minor's personal information under this Privacy Policy, and You personally accept and agree to be bound by the policy. Additionally, You agree to be responsible for the minor's conduct and ensure their compliance with this Privacy Policy.

Your Rights. Right to access: You have the right to access and obtain a copy of your personal information that we have collected or is being processed by us or on our behalf. We reserve the right to charge a legally permissible fee for providing access to your personal information.

When processing data access requests, we may ask requesters to provide specific information to verify their identity and confirm their entitlement to request access to the data as the data subject.

Right to correction: You may request corrections to your personal information. When processing data correction requests, we may ask requesters to provide specific information to verify their identity and confirm their entitlement to request corrections to the data as the data subject.

Right to restrict the processing of your personal information: You may request a restriction on the processing of your personal information by contacting us through the contact details provided. However, such processing restrictions may impact our ability to provide You with the appropriate services or Platform features.

Singapore

By clicking "Accept," You consent to the international transmission of your information to any country or region where we have databases or affiliates, particularly in the People's Republic of China and Japan.

Thailand

By accepting this Privacy Policy, You acknowledge that You have read, understood, and accepted this Privacy Policy. Please refrain from using our services if You do not agree to this Privacy Policy.

Please do not use our services without the permission of your parent or guardian if You are under 20 years of age.

The Philippines

You may exercise your rights and freedom as a data subject to the extent permitted by laws, rules, and regulations, and You may query, access, correct, delete, or mask your personal information. You may also file a complaint with the National Privacy Commission (NPC) to request damages and exercise your right to data portability. We may require verification of your identity or account information before responding to your request to exercise one or more such rights.

Vietnam

By accessing and/or using our services, You confirm that You are at least 16 years of age and no longer require the supervision of a guardian. If You are under the age of 16 or under the supervision of a guardian, before accessing and/or using our services:

•You must obtain consent from your parents or legal guardians; and

•Your parents or legal guardians shall be responsible for: (i) all of your activities while using and accessing the Platform, including through accounts created using the parents' or guardians' names, and supervising all your account activities; (ii) ensuring your compliance with this Privacy Policy; and (iii) ensuring that your activities do not violate applicable child protection laws under any circumstances.

You must stop accessing and using this Platform if You have not obtained the consent of your parents or legal guardians or if they are unwilling to create an account using their own name.

Canada

If You reside in Canada and wish to obtain more written information about our policies and activities involving service providers outside Canada, You may contact us through the online customer services provided on this Platform or the customer services in specific games. Our privacy specialists responsible for managing this email address can also answer users' questions about the collection, use, disclosure, and storage of personal information by our service providers.

We will require any service providers we use who have access to your personal information to abide by privacy and security standards comparable to our own. We maintain the confidentiality and security of your personal information by entering into agreements with our service providers and taking other precautions to prevent the use of your personal information for purposes other than those outlined in this Privacy Policy.

Japan

If you are under the age of 18, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Game.

International Data Transfer. By acknowledging the Privacy Policy, you consent to 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 China. If we transfer your data outside of Japan to a country that is not recognized by Personal Information Protection Commission as establishing a personal information protection system recognized to have equivalent standards the same in Japan, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the reasonable standard measures following the requirements of Section 1 of Chapter 4 in Japanese APPI. You may ask for a copy of such appropriate measures by contacting us by contacting to Chief Privacy Officer. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.

Your Rights. You have a right to request disclosure of your personal data retained by us (“Retained Personal Data”) and purpose of use thereof, disclosure of records of third parties transfer, correction, addition, deletion, and discontinuance of the use and third parties transfer of the Retained Personal Data. To make a request concerning your rights above, please contact us by sending an email to Chief Privacy Officer(privacy@krafton.com). In special cases (i.e. request your rights through mailbox, etc.), we may demand a fee when you request your rights.

Republic of Korea

We transfer personal information to third parties overseas as follows:

You may refuse the overseas transfer of your personal information by contacting our Data Protection Department. If you refuse the overseas transfer of your personal information, your personal information will not be transferred overseas. However, you may not be able to use our services for which overseas transfer of personal information is necessary.

Data Retention. The personal information detailed in this Privacy Policy are required to be retained pursuant to the following laws:

Your rights. 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.