MechaBREAK PRIVACY POLICY

MechaBREAK PRIVACY POLICY

 

Last Updated: 2025/06/13

 

This Privacy Policy (the "Policy") explains when, how and why your personal data in connection with the online game Mecha BREAK (the "Game") is processed, whether it is played on PC, our website or other approved platforms. Please read this Policy carefully as it is important for you to understand how we collect and use your data and how you can control it. 

In this Policy, "we," "us" and "Seasun" refer to:

i. SEASUN GAMES PTE. LTD., governing users of Amazing Seasun Games; and

ii. Seasun Inc., governing users accessing our services through third-party distribution platforms, including but not limited to Steam,Xbox and Google.

This Policy deals with where we are acting as a "Data Controller" under the data protection legislation, that is, where we are responsible for deciding what personal data we collect and how we use it. In some cases, our Affiliates may be considered data controllers.

"Personal Data" refers to any information that can be used to identify you either directly or, in combination with other data.

"Affiliates" refer to entities that directly or indirectly control, are controlled by or are under the common control of SEASUN.

We are committed to protecting and respecting the personal data of everyone we deal with—which is important to both us and you.

In this Policy, you will find information about what types of personal data we hold about you, how and why we collect it, how we use it, and how we keep it secure. You will also find here information about your rights and how you can exercise them.

If you reside or use our Game in a country or region specifically mentioned under the Section "Country/Region-Specific Terms" below, those terms and conditions under the relevant country/region shall specifically apply to you.

Please read this Policy carefully. For any inquiries regarding this Policy or your personal data, contact us by email at MechaBREAKDataProtection@seasungames.com.

 

1 Parental and Guardian Consent

2 What Data We Collect, How We Use It and The Legal Basis

3 To Whom We May Disclose or Transfer Your Data

4 Data Storage and Retention

5 International Data Transfer

6 Your Rights and Choices

7 Data Security and Protection

8 Updates to This Policy

9 Contact Information

SUPPLEMENTAL TERMS: Country/Region-Specific Terms

California Residents

Japanese Residents

Korean Residents

 

1 Parental and Guardian Consent

OUR SERVICES ARE NOT INTENDED FOR CHILDREN UNDER THE MINIMUM AGE, NOR DO WE KNOWINGLY COLLECT DATA FROM CHILDREN BELOW THIS AGE.

1.1 ANYONE UNDER THE AGE OF 13 (UNITED STATES/JAPAN/UNITED KINGDOM)/14 (KOREA)/16 (EUROPEAN UNION) OR THE MINIMUM AGE OTHERWISE DEFINED BY THE APPLICABLE LAWS OF YOUR JURISDICTION ("MINIMUM AGE") SHALL NOT CREATE A GAME ACCOUNT ("ACCOUNT") AND USE OUR GAME. WE ALSO DO NOT KNOWINGLY COLLECT OR STORE ANY PERSONAL DATA ABOUT CHILDREN UNDER THE MINIMUM AGE WITHOUT PARENTAL PERMISSION.

 

1.2 If you are a minor in your country or region, your use of our Services may be subject to further age restrictions, whether imposed by us or third-party vendors in connection with the provision of certain Services. You may be unable to use or only have limited access to those Services, such as, where applicable, games with age restrictions, participation in rewards programs and topping up without the assistance of your parents or legal guardian.

 

1.3 If you learn that a child under the Minimum Age has registered an Account or an Account of a minor under the Minimum Age was not registered under proper supervision, representation or guardianship, you may alert us at MechaBREAKDataProtection@seasungames.com. We will promptly investigate and take steps to erase such minor's Account information and terminate the Account.

 

2 What Data We Collect, How We Use It and The Legal Basis

We collect personal data to the minimum scope necessary for the provision of the Game. The personal data we collect may be provided by you or, in case of usage data, collected automatically when using our Services.

 

2.1 Setting up and signing in

When you set up or sign into our Game with your Seasun Games account, your personal data such as your email address may be collected to create your Account and store your game data and gameplay progress. Please carefully read the "Amazing Seasun Games Privacy Policy" before setting up your account.

When you sign into our Services via your third-party platform account (for example, Steam ID), we may collect personal data that you have agreed to share via social media or third-party platforms, such as your nickname, user ID and user token. Such data obtained from third-party social media providers will be added to your account information.

The processing activity is necessary for the performance of the contract between you and us.

 

2.2 Age restriction

We will verify your age to confirm whether we can provide you with our services,and limit your top-up amount(Japan and Republic of Korea only).

It is necessary for us to be compliance with any legal or regulatory obligations under any applicable laws.

 

2.3 Website-based services

In order to enhance your access speed, we will collect your Website Ping Rate to recommend a server that is closer to you. You also have the option to choose a server other than the recommended one.

The processing activity is necessary for the performance of the contract between you and us.

 

2.4 Fairness, security and service improvement

To ensure security and stable operation, resolve bugs or errors, provide a fair gaming environment, prevent cheating and improve the functionality and quality of our Services, we may collect specific information about your device, such as your browser type, Mac address, language and version, operating system, error and service access logs, time zone settings, CPU, GPU, RAM, network type, Wi-Fi information and user action logs on the platforms.

The processing activity is based on our legitimate interest.

 

2.5 Game data

When you play the Game, your in-game profile data, player UID, gameplay, and statistics are collected. Some of this information may be visible to other in-game players.

The processing activity is necessary for the performance of the contract between you and us.

 

2.6 Community communication

Microphones are turned off by default. You can enable them to communicate with other players. To facilitate community communication within the game, we may collect your personal data, such as text, audio, and/or other electronic communications.

We may also use such personal data for the purpose of detecting and preventing violations of our Terms of Service, unauthorized activity or other security risks, and illegal, fraudulent, offensive, inappropriate, or other harmful behavior.

Please take note that this communication data may be accessed, copied, or used by other players under certain circumstances—such as when you engage in a chat during a live-streamed match.

When participating in our Game, please also be aware that certain personal details, including your gameplay statistics and performance metrics, will be visible to other players.

The processing activity is based on your consent.

 

2.7 Payment

In order to enable you to buy virtual items and use the payment service, we will collect your purchase order details and payment data which provided by a third party when you make purchases with your Account, such as product details, product prices, purchase amounts, transaction order ID, product types, order expiration time, transaction tax, number of order price changes, and the highest bidder's player ID.

The processing activity is necessary for the performance of the contract between you and us.

 

2.8 Customer support

When you contact us for customer support, we need to collect your personal data, such as your email address, player UID, region, server, platform type, issue description and communication records of the issues you experience.

The processing activity is necessary for us to locate and resolve issues; that is, for the performance of the contract between you and us.

 

2.9 Newsletter ,or promotion and advertisement

When you subscribe to our newsletter or promotional information, we may collect your email address to send you messages.

The processing activity is based on your consent.

In addition, we may automatically record your activity logs on relevant web pages, products, etc., such as your active retention time, user ID and other information, through cookies or similar technologies (such as web beacons, tracking pixels, etc.) or embedded scripts like SDKs. This is used to assist us in user identification and data analysis, so as to improve our services. This activity processing is based on our legitimate interests.

 

2.10 Contest

When you participate in a contest organized by us, we will collect personal data that you have agreed to provide, such as your email address, only for the administration of the contest.

The processing activity is based on your consent.

 

2.11 Teammate Recommendation

We will recommend friends and teammates to you who share similar interests and behavioral patterns based on your login habits, gaming behavior data and social interaction data within the Game, using a personalized recommendation algorithm. You can object personalized recommendations by contacting MechaBREAKDataProtection@seasungames.com or through our online customer service.

The processing activity is based on your consent.

 

2.12 Survey

When you participate in our survey, we will collect your email address and feedback to help us improve the quality of our products and services.

The processing activity is based on our legitimate interests in improving our products and services.

 

Our legitimate interests

We also process your personal data based on our legitimate interests as a commercial organization. Our legitimate interests include maintaining and administrating the services, providing the services to you, improving the content of our products and services, ensuring your account is adequately protected, and complying with any contractual, legal or regulatory obligations under any applicable laws.

 

Other legal bases

Beyond the aforementioned legal basis for processing, we may process your personal data when:

l Processing is necessary for compliance with a legal obligation to which we are subject;

l Processing is necessary to protect the vital interests of the data subject or of another natural person;

l Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;

l Processing is for scientific or historical research purposes or statistical purposes in accordance with applicable laws.

For the purposes set forth above, our Affiliates may be commissioned to process your data, provided that such Affiliates comply with the terms in this Policy.

 

3 To Whom We May Disclose or Transfer Your Data

 

3.1 We will not disclose or transfer your data to any third parties except as explicitly provided in this Policy. We will share your data with third parties only when:

(i) you (or your parent/legal guardian) have approved;

(ii) as required for administrative or judicial purposes, including any requirements of competent authorities, courts and regulatory bodies;

(iii) necessary to protect our legal rights in proceedings against you;

(iv) permitted under the terms of service;

(v) required to protect our, your, or public interests; or

(vi) pursuant to the agreements made by you with any other third parties.

 

3.2 We may share your data with our Affiliates, group members, and service providers who will only use your data in accordance with this Policy to facilitate the provision of our Services to you or for other purposes as indicated below.

(i) Affiliates

Seasun is a global company and has Affiliates all over the world. In order to provide our Services, we will share your personal data with our Affiliates based on the respective legal basis and data processing agreements signed between us.

(ii) Sale or merger

A third party that acquires all or substantially all of us or our business. We will disclose data to a third party in the situation that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose data to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, personal data may be among the transferred assets. You will be notified via email, in-game notice and/or notice on our Website of any change in ownership or users of your personal data.

(iii) Social media platforms

You may choose to log in to the Game with your social media (such as Facebook, Google, X and Apple) account in order to take advantage of additional social features. We may share necessary data to enable your log-in.

If you allow social media integration with our Game or share the content of Services on third-party platforms (such as Facebook and X), we may share certain necessary data (such as account ID and user ID) with the platform you choose, depending on the content you decide to share.

(iv) Law enforcement/legal obligation

(1) Anti-cheat and anti-fraud companies

We may share data required for our detection, investigation and prevention of cheating in the Game and Terms of Service violations only for the purposes of detection, investigation and prevention of cheating in the Game.

(2) Legal, regulatory or government authorities

We may in limited cases transfer game information to local (where you reside) or overseas authorities such as legal, regulatory, law enforcement, government and tax authorities, to satisfy our obligations or those of third parties (when they receive a request from an authority empowered by law to do so), pursuant to applicable laws and regulations.

(v) Third parties to support our Game

We may engage or partner with third parties to provide services. We share your information with these service providers hosting or operating our Services, payment and transaction processing, rewards, vouchers and delivery of commercial goods (where applicable), cloud services, e-mail communications, security risk control, research, survey, marketing and information analysis services. We share your data only on a need-to-know basis with third parties so that they can perform the relevant functions and services, and we require such parties to take appropriate security measures to protect your data from unauthorized access or processing.

(vi) Promotion service provider

If you choose to register for a promotion, such as a competition, sweepstakes, lucky draw, contest and reward program for users or creators, your information may be disclosed to third parties for the purposes of supporting and administering such promotion.

 

3.3 Except as otherwise provided in this Policy, we will not disclose any data collected from your use of our Services to the public. If public disclosure is required by applicable laws and regulations, we will inform you of the purpose of the disclosure and the type of data disclosed.

 

4 Data Storage and Retention

4.1 Our Game's servers are strategically located in various countries, including but not limited to the United States, Germany, Singapore, Turkey and Poland. The servers applicable to you depend upon your location.

4.2 We will retain your data only while your account is active or as needed to provide you with game services unless you request deletion of such data or the law requires otherwise. Retention purposes include:

 (i)  Achieve the purposes as set out in this Policy;

 (ii) Meetting applicable laws and regulations, including any requirements to retain data for a certain period of time, taking into account the statute of limitations under applicable laws and regulations. 

(iii) Serving our legitimate and lawful purposes, including for our business, and provision of Seasun Games Website/Installer; and/or

(iv) Defend against any actual, threatened or potential claims or disputes.

4.3 If you opt out from marketing, we will retain your data to ensure compliance with your marketing preferences.

 

5 International Data Transfer

In order to provide you with the Services and operate our global business,we may transfer your personal data to our Affiliates, third party service providers and partners that operate around the world, which are located in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.We ensure to take appropriate safeguards to keep your personal data protected in accordance with this Privacy Policy such as incorporating standard contractual clauses, before any cross-border transfer of your data takes place.

Data Sharing and Third-Party Disclosures

We only disclose your personal data to third parties when necessary and in compliance with the principles of purpose limitation, data minimization, and accountability:

(i) We may share your data with our Affiliates in other jurisdictions solely for the purpose of providing the Service to you. We implement rigorous internal control measures in place to strictly limit data access to designated personnel only,and all such Affiliates may only use your personal data in accordance with this Privacy Policy

(ii) To provide Seasun Games Website/Installer to you, we may transfer your data internationally to third-parties that provide services in support of the Service, including providers of cloud services, payment services, analytics,strictly following international transfer mechanisms permitted under applicable laws and regulations. They are subject to contractual obligations to process such data only in accordance with our instructions and applicable data protection laws.

 

6 Your Rights and Choices

6.1 Under applicable laws and regulations, you may have the right to access, rectification, erasure, and certain other rights in relation to your personal data that we collect and process (hereinafter referred to as the "Request"). These rights will be subject to specific exclusions and exceptions under applicable laws.

(i) You have the right to be informed in a concise, transparent, intelligible and easily accessible form of the way in which your data is processed. You also have the right to obtain confirmation as to whether your data is being processed, and where that is the case, to access such information and obtain a copy thereof.

(ii) You have the right to request rectification of your data. You also have the right to have incomplete data completed, and have the data out of date updated.

(iii) You have the right to request us to erase some or all your personal data.

(iv) Where you have provided your consent, you may withdraw your consent. If you withdraw your consent, we may continue processing your data to the extent permitted by applicable laws.

(v) You have the right to request us to restrict the further processing of your personal data. In such cases, the respective data will be marked as restricted, and may only be processed by us for certain purposes.

(vi) You have the right to object, on grounds relating to your situation, to the processing of your personal data by us, and we may be required to no longer process some or all your personal data. You have the right to object to the processing of your personal data for direct marketing purposes.

(vii) You have the right not to be subject to a decision based solely on automated processing where the decision has a significant legal impact on you.

(viii) You have the right to receive a copy of your personal data which you have provided to us, in a structured, commonly used, and machine-readable format, and you have the right to request the transfer of that personal data to another entity without hindrance from us.

(ix) You can ask us to delete your Account, which is an irreversible process as you will not be able to access your Account upon deletion, and all data in relation to the Account will be deleted or de-identified, subject to any statutory retention requirements under applicable laws and regulations.

 

You may also have other rights as described under the "Country/Region-Specific Terms" section below or otherwise under local laws.

 

6.2 Before fulfilling your Request, we will verify your identity. We will respond to your Request within legal timeframes. We may refuse your Request (for example, if your Request may infringe on the privacy of others, exceed the provisions of applicable laws, etc.), and when we refuse, we will inform you of the specific reasons. For unresolved concerns, you can hand over the complaint to the data protection regulatory authorities in your jurisdiction. We'll provide relevant complaint mechanism information upon request.

 

6.3 If you are one of our customers or have otherwise agreed to be contacted for marketing purposes, we may use your personal data to send you information about us and our Services. You can unsubscribe from receiving direct marketing at any time and details of how to unsubscribe will be included in any marketing communications we send you. You also have the option of "unsubscribing" from our mailing list at any time, thereby disabling any further such email or other communication from being sent to you by emailing MechaBREAKDataProtection@seasungames.com.

 

7 Data Security and Protection

We will take appropriate technical and organizational measures to help protect and secure your data. We will endeavor to protect your data against unauthorized or unlawful processing, accidental loss, destruction, and damage through measures including:

(i) Data encryption;

(ii) establishing specialized systems and procedures, such as strictly limiting the scope of personnel with access to your data and requiring those who have such access to comply with relevant confidentiality obligations; and

(iii) forming a specialized department in charge of information security. In the event of incidents such as information leakage or data or security breach, we will take timely measures to handle such incidents, and we will notify you promptly in an appropriate manner in accordance with applicable laws and regulations.

We collect and process only data needed for Game services by default. Our privacy controls follow this principle - we neither share nor publish your data unless necessary.

While we are committed to protecting your data, no electronic data transmission or storage can be completely secure. If you do not accept these risks and conditions, please discontinue the Game use.

 

8 Updates to This Policy

We may update, change or modify this Policy from time to time,and such changes shall from a part of this Policy . You'll be notified through Service announcements or login notifications when you log in to or update the software. Updates are effective upon notification and apply to all data unless stated otherwise.

For significant changes affecting your rights, we will notify you and obtain your consent.

 

9 Contact Information

For any complaints, suggestions or inquiries regarding this Policy or the collection, usage, storage, protection and other functions of your data, please emailing:

• Data Protection Officers

• Email address: MechaBREAKDataProtection@seasungames.com

We will respond to your inquiry as soon as possible,within the timeframes required by applicable laws. If you are not satisfied with our response to your privacy or data protection concern, please submit a complaint to our independent U.S.-based dispute resolution provider at no cost to you: https://feedback-form.truste.com/watchdog/request

 

California Residents

The California Consumer Privacy Act (CCPA) grants consumers residing in California certain rights with respect to their personal data. We are committed to respecting the following rights and complying with the CCPA. As a California resident, you may have the right to: (i) request to know more about the categories and specific pieces of personal data we collect, use, and disclose; (ii) request deletion of your personal data; (iii) opt out of sale of your personal data (if any); and (iv) not be discriminated against for exercising these rights.

For details about the precise information, we may collect and the categories of sources where we got that information during the past 12 months, please refer to "2 What Data We Collect, How We Use It and The Legal Basis" above. We collect personal data for the purposes described in "2 What Data We Collect, How We Use It and The Legal Basis" above.

You have the right to request deletion of your personal data. Please note that your request for data deletion may impact your use of our Game in some cases, and we may decline to delete information for reasons set forth in this Privacy Policy or as permitted by the CCPA.

Our Game does not sell the personal data we collect and has not done so in the past 12 months. However, we may disclose personal data as described in "3 To Whom We May Disclose or Transfer Your Data" above. We do not share or use personal data for targeted advertising purposes in the US states where such activities required opt-out options.

We will not discriminate against you for exercising your rights under the CCPA.

If you have any questions or require assistance, you may contact us at: MechaBREAKDataProtection@seasungames.com

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Japanese Residents

By accepting this Privacy Policy, 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 .

Korean Residents

Collection and Use of Personal Information

We collect your personal information for the purposes described in this Privacy Policy.  Personal information that we collect from Republic of Korea is stored in and processed on our server located in Singapore and Japan.

With regards to the legal basis of processing personal information included in Section 3 “How We Process Your Personal Information,” the following legal provisions under the PIPA applies:

• (for consent): we use this information pursuant with your consent, pursuant to Article 15(1)(1) of the PIPA.

• (for complying with legal obligations): we use this information where necessary to comply with a legal obligation pursuant to Article 15(1)(2) of the PIPA.

• (for contractual necessity): we use this information where necessary to perform our contract with you to provide our Services, pursuant to Article 15(1)(4) of PIPA.

• (for legitimate interest): we use this information where it is in our legitimate interest pursuant to Article 17(1)(2),15(1)(6) of PIPA.

 

Third-Party Provision of Personal Information

We provide your personal information to third parties as described below:

We provide your personal data to third parties as described below:

Legal Grounds

Recipient

Types of personal data Provided

Purpose of Use by Recipient

Period of Retention and Use by Recipient

for contractual necessity- PIPA Art. 15(1)(4)

Valve Corporation

(https://store.steampowered.com/privacy_agreement/?snr=1_44_44_)

(For steam users only)

UID,Purchase order’s detail

In-game purchase

Until the purposes as set out in valve Privacy Policy are achieved or until the termination of relevant contracts.

 

Goolge LLC

(https://policies.google.com/privacy)

(For Google users only)

UID,Purchase order’s detail

In-game purchase

Until the purposes as set out in Google Play’s Privacy Policy are achieved or until the termination of relevant contracts.

Microsoft Corporation

(https://www.microsoft.com/zh-cn/privacy/privacystatement)

(for Xbox users only)

UID, item ID and name

In-game purchase

Until the purposes as set out in Xbox’s Privacy Policy are achieved or until the termination of relevant contracts.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

for contractual necessity- PIPA Art. 15(1)(4)

RAZER ONLINE PTE. LTD.

(https://www.razer.com/sg-en/legal/customer-privacy-policy?srsltid=AfmBOoq6Gk2Ukiht-QDju4qcOtaGg7G_g8KmEpMY8nuCe78akRpjtwX8)

Purchase order’s detail

Provide payment service.

 

Until the purposes as set out in razer Privacy Policy are achieved or until the  termination of relevant contracts.

AIRWALLEX (SINGAPORE) PTE. LIMITED

(https://www.airwallex.com/au/terms/privacy-policy#scope-of-policy)

Purchase order’s detail

Provide payment service.

 

Until the purposes as set out in Airwallex Privacy Policy are achieved or until the  termination of relevant contracts.

Adyen Singapore Pte Ltd.

Adyen N.V.

(https://www.adyen.com/en_SG/privacy-policy)

Purchase order’s detail

Provide payment service.

 

Until the purposes as set out in adyen Privacy Policy are achieved or until the  termination of relevant contracts.

PayPal Hong Kong Limited

Purchase order’s detail

Provide payment service.

 

Until the purposes as set out in Paypal Privacy Policy are achieved or until the  termination of relevant contracts.

Legitimate interest – PIPA Art. 17(1)(2),

Gamesight Inc.

(https://docs.gamesight.io/docs/data-security)

 

Analytics and profiling data

Perform data analytics and  advertising measurement.

In accordance with the Gamesight privacy policy

 

Delegation of Personal Information

For the performance of the services detailed in this Privacy Policy, we delegate the processing of your personal data to the following professional service providers:

Delegatee

Description of Delegated Services

Google LLC

Storage of personal data 

Alibaba Cloud (Singapore) Private Limited

Storage of personal data

Aceville Pte. Ltd

Detecting and preventing violations of our Terms of Service, unauthorized activity or other security risks

HighRas Limited

Identify inappropriate in-game behaviour that insults and abuses other users

 

Overseas Transfer of personal data

We transfer personal data to third parties overseas as follows:

Legal Grounds

Recipient

Country to which Your personal data is to be Transferred

Date and Method of Transfer

Types of Your personal data to be Transferred

Purposes of Use by Recipient

Period of Retention of Use by Recipient

for contractual necessity- PIPA Art. ,15(1)(4)

 

Valve corporation

(For steam users only)

In accordance with Steam's privacy policy

(https://store.steampowered.com/privacy_agreement/?snr=1_44_44_)

Transferred via information and communications network at the time of service use

UID、item ID、IP address

In-game Purchase

Until the purposes as set out in valve    Privacy Policy are achieved or until the termination of relevant contracts.

Goolge LLC

(For Google users only)

In accordance with google’s privacy (https://policies.google.com/privacy)

Transferred via information and communications network at the time of service use

UID,Purchase order’s detail

In-game Purchase

Until the purposes as set out in google    Privacy Policy are achieved or until the termination of relevant contracts.

Microsoft Corporation

(for Xbox users only)

In accordance with Xbox’s privacy policy (https://www.microsoft.com/zh-cn/privacy/privacystatement)

 

Transferred via information and communications network at the time of service use

UID, item ID and name

In-game Purchase

Until the purposes as set out in MicrosoftPrivacy Policy are achieved or until the termination of relevant contracts.

PIPA Art. 28-8(1)(3) Delegation and Retention for Contract Performance

 

Google LLC

(https://policies.google.com/privacy)

Singapore

Transferred via information and communications network at the time of service use

User registration and payment Information

Storage of personal data

Until the purposes as set out in this Privacy Policy are achieved or until the termination of relevant contracts.

Legitimate interest – PIPA Art. 17(1)(2), 15(1)(6)

 

 

Aceville Pte. Ltd

 

In accordance with Aceville's privacy policy

Transferred via information and communications network at the time of service use

User communication Information

Detecting and preventing violations of our Terms of Service, unauthorized activity or other security risks

Until the purposes as set out in this Privacy Policy are achieved or until the termination of relevant contracts.

HighRas Limited

In accordance with HighRas's privacy policy

Transferred via information and communications network at the time of service use

Communication content

Identify inappropriate in-game behaviour that insults and abuses other users

Until the purposes as set out in this Privacy Policy are achieved or until the termination of relevant contracts.

PIPA Art. 28-8(1)(1) Consent of the Data Subject

 

Legitimate interest; contractual necessity – PIPA Art. 17(1)(2), 15(1)(6) ,15(1)(4)

 

 

RAZER ONLINE PTE. LTD.

The United States

Transferred via information and communications network at the time of service use

User payment information

Assisting users with the completion of in-game payments.

Until the purposes as set out in this Privacy Policy are achieved or until the termination of relevant contracts.

AIRWALLEX (SINGAPORE) PTE. LIMITED

In accordance with Airwallex's privacy policy

Transferred via information and communications network at the time of service use

User payment information

Assisting users with the completion of in-game payments.

Until the purposes as set out in this Privacy Policy are achieved or until the termination of relevant contracts.

Adyen Singapore Pte Ltd.

Adyen N.V.

In accordance with Adyen's privacy policy

Transferred via information and communications network at the time of service use

User payment information

Assisting users with the completion of in-game payments.

Until the purposes as set out in this Privacy Policy are achieved or until the termination of relevant contracts.

PayPal HongKong Limited

The United States

Transferred via information and communications network at the time of service use

User payment information

Assisting users with the completion of in-game payments.

Until the purposes as set out in this Privacy Policy are achieved or until the termination of relevant contracts.

Legitimate interest – PIPA Art. 17(1)(2), 15(1)(6)

 

Gamesight Inc.

The United States

Transferred via the information and communication network during service utilization.

User device information, account information, game server information, and behavior information

Data analysis and advertising attribution

Until the purposes as set out in this Privacy Policy are achieved or until the termination of relevant contracts.

You may refuse the overseas transfer of your personal data. If you choose to do so, your personal data will not be transferred overseas. However, you may not be able to use our Services for which overseas transfer of personal data is necessary.

 

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed in section “Data Storage and 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.

Personal data 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

· Records regarding labeling and advertising (6 months)

· Records regarding execution or withdrawal of a contract (5 years)

· Records regarding 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 addresses (3 months)

· Dates of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

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, or objecting to or requesting an explanation on an automated decision concerning 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.  Pursuant to Articles 15(3) and 17(4) of the PIPA, we consider the following factors set forth in Article 14-2 of the Enforcement Decree of the PIPA when using or providing to a third party additional personal information without your consent:

• whether the additional use/provision is related to the initial purpose of the collection;

• whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;

• whether the additional use/provision unfairly infringe on the interests of the data subject; and

• whether the necessary security measures such as pseudonymization or encryption were taken.

 

Measures to Ensure Safety of Personal Information

We implement the following measures to ensure safety of your personal information:

• Managerial measures: establishment and implementation of internal management plan, operation of dedicated organization, regular employee training

• Technical measures: management of access rights to the personal information processing system, installation of an access control system, encryption of personal information, and installation and renewal of security programe;

• Physical measures: access control of computer rooms, data storage rooms, etc.

 

Remedies for Infringement of Rights

1. You can apply for dispute resolution or consultation regarding personal data infringement by contacting the Personal Information Dispute Mediation Committee, the Personal Information Infringement Report Center of the Korea Internet & Security Agency, or other related institutions. To report or consult on personal data infringement, you can contact the following institutions:

· Personal Information Dispute Mediation Committee: 1833-6972 (without area code) (www.privacy.go.kr)

· Personal Information Infringement Report Center: 118 (without area code) (privacy.kisa.or.kr)

· Supreme Prosecutors' Office Cyber Investigation Department: 1301 (without area code) (www.spo.go.kr)

· National Police Agency Cyber Bureau: 182 (without area code) (ecrm.police.go.kr)

 

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