Tower of Fantasy

Privacy Policy

Last Updated: 30 June 2023

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to the game Tower of Fantasy (“Game”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

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

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

SUMMARY

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

What information do we need to be able to provide the Game?	·       If you register an account to use the Game, we will need some information from you to set this up. If you register for a Level Infinite Account, this includes a username and email address. We will generate an Open ID, which is an internal ID for your account. If you register via a third-party platform account, this includes your third-party platform user ID, user token, nickname and profile picture. We will generate an Open ID, which is an internal ID for your account. Depending on your use of the Game and the jurisdiction where you are based, you may also need to provide some additional information to help us set up your account. ·       To maintain the smooth operation of the Game (which includes activities such from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information (such as IP address, device specifications, as well as app- and OS-generated identifiers). ·       If you choose, you can provide other information to personalise your experience of the Game or enable Game features. This includes chat, sharing or notification information. ·       If you agree, you can also choose to participate in promotional events we organise in relation to the Game, such as giveaways, contests, draws or other similar events. ·       If you need to get in touch with us, we will retain some information (such as any screenshots you send us) so that we can review and respond to your concerns.	More Information.
How will we use your information?	·       We use your information to set up your account, enable you to use the Game, localise the Game experience, enable interaction between users of the Game, save your progress, ensure the safe and secure operation of the Game (including, for instance, detect cheating behaviour to provide a fair environment),address bugs, optimise and improve the Game, conduct surveys, send notifications of game events and updates, conduct game-related events such as giveaways, contests, draws or other similar events, monitor our marketing initiatives, enable transactions, resolve user queries, and to comply with our legal obligations and enforce our legal rights.	More Information.
Who do we share your information with?	·       We use third parties and work with our affiliates to help us deliver the best possible experience (such as for data storage, for customer support, payment processing, to provide push notifications, voice message and speech-to-text and translation services, and surveys and our marketing). ·       All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game (i.e., to fulfil the purpose(s) described above). ·       In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.	More Information.
Where do we process your information?	·       Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. ·       We have servers for the Game in Singapore, the United States, Brazil, Japan and Germany. The servers applicable to your use of the Game will depend upon your location or selection. We also have support, engineering and other teams who may support the Game, including from Singapore. ·       For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent first or taking into account adequacy assessments.	More Information.
How long do we keep your information?	·      Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Game, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.	More Information.
How can I exercise my rights over my information?	·       Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.	More Information.
How will we notify you of changes?	·       Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.

Welcome to Tower of Fantasy!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the game Tower of Fantasy (the “Game”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Game. If you use any other products or services please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Game. By using the Game you are acknowledging how we process your personal information as described in this Privacy Policy.

 

For the purpose of data protection laws, the data controller of your personal information in relation to the Game is Proxima Beta Pte. Limited (“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer using our online form for submitting data privacy related request and question at https://dsar.toweroffantasy-global.com/tchk?id=tof. We have representatives for data protection purposes listed here.

1.            Children

Children must not use the Game for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction). Except with such consent, children must not use the Game for any purpose. If you are a parent of a child who has signed up with your consent and you would like to understand more about the Game or how you can revoke your consent, please refer to the section “Information for Parents” below.

By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

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

Region in which the user is located	Minimum age of the user
Algeria	19
Argentina	13
Australia	18
Bangladesh	18
Brazil	18
Colombia	18
Cambodia	18
Canada	13
Egypt	18
European Economic Area	16
India	18
Indonesia	21
Japan	18
Kuwait	21
Malaysia	18
Mexico	18
Morocco	18
Myanmar	18
New Zealand	16
Nigeria	13
Philippines	18
Qatar	18
Russia	14
Saudi Arabia	18
Serbia	15
Singapore	13
South Africa	18
Sri Lanka	18
Switzerland	16
Thailand	20
Tunisia	18
Turkey	18
United Arab Emirates	21
United Kingdom	13
United States	13
Vietnam	16

 

2.            How We Process Your Personal Information

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

For users who live in Brazil, the European Economic Area, Switzerland, Thailand, Turkey or the United Kingdom, it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (where applicable)
Information you provide to us (either directly or through a third party)
Level Infinite Account log-in information (if you choose to log-in via Level Infinite Account): UID, token, email, username https://account.levelinfinite.com/privacypolicy.html	We use this information to link your Tower of Fantasy account to your Level Infinite Account in accordance with your request.	Necessary to perform our contract with you to provide the Game.
Third party platform log-in information (if you choose to log in via your third-party platform account with these networks): ·       Facebook: Dummy versions of your Facebook UID, name, profile picture, user token, and Open ID ·       Google Play: User ID, nickname, profile picture, user token, and Open ID ·       Twitter: User ID, nickname, profile picture, user token and Open ID ·       LINE: User ID, nickname, profile picture, user token and Open ID ·       Apple: User ID, nickname, profile picture, user token and Open ID ·       Steam: User ID, nickname, profile picture, user token and Open ID ·       Epic: User ID, nickname, profile picture, user token and Open ID	We use this information to create your account for the Game in accordance with your request and to facilitate your logins.	Necessary to perform our contract with you to provide the Game.
Survey information: gender (optional), age range (optional), country or region of residency (optional), income information (optional), phone number (optional), email address (optional), nickname (optional), any other content you choose to provide as part of the survey response. To the extent you choose to participate in an in-game survey regarding the Game services, we will redirect you to IMUR Survey to take the survey and the IMUR Survey privacy policy will apply to certain data processed in connection with your participation in the survey. You can read more in the IMUR Survey privacy policy available at the link above under The Types of Personal Information We Use – Survey Information.	We use this information to better understand our users and to improve the Game services.	We collect this information with your consent.
Events-related information: User ID, phone number, email address, mailing address, and any other content you choose to provide as part of the events in which you participate. To the extent you choose to participate in our promotional events such as giveaways, contests, draws or other similar events, you may be requested to provide certain information related to the event, such as answers to quizzes or comments, and contact information. We will ask for your contact information if you are selected as a winner and only use such information if you agree to provide them to receive gifts or prizes. Some of the events-related information will be processed through our customer service when you contact us.	We use this information to conduct our events, including to: ·       identify participants; ·       select winners; and ·       send you gifts or prizes if you are selected as a winner.	We collect this information with your consent.
Information generated as part of the Game
Guest log-in information: Guest ID, Open ID	We use this information to create your account for the Game in accordance with your request.	Necessary to perform our contract with you to provide the Game.
Open ID (game data)	We use this information to: ·       identify user logs; ·       store your game data with your profile; and ·       allow you to connect to our server.	Necessary to perform our contract with you to provide the Game.
Gameplay statistics: player level, in-game performance (combat effectiveness, equipment and combat duration), virtual currency	We use this information to allow you to play the game, to document and save details of your use for future gameplay and to provide you with feedback and information about your gameplay and progress.	Necessary to perform our contract with you to provide the Game and to document and save details of your use for future gameplay.
IP address	We use this information to allow you to connect to our server and recommend the closest server for your selection.	Necessary to perform our contract with you to provide and support the Game.
Game log information: For mobile version: Character ID, game account (used when you log in to the Game), user nickname, country code, device system version, device brand, device model, device manufacturer, device name, screen resolution, screen orientation, CPU model, graphics processing unit information, RAM, client exports IP, phone memory, login channel ID, operator name, network type, signal strength, and network-signal-related data For PC version: Character ID, game account (used when players log in to the Game), user nickname, country code, device system version, device brand, device model, device manufacturer, device name, screen resolution, screen orientation, CPU model, graphics processing unit information, RAM, client exports IP, disk memory, login channel ID, network type and network-signal-related data	We use this information: ·       to maintain a record of log-in and actions of the user account; ·       to improve our services, including the functionality of the Game; and ·       for security and verification purposes.	Necessary to perform our contract with you to provide the Game and to document and save details of your use for future gameplay. To the extent we process the information for improving our services, this is based on our legitimate interest to do so.
Text chat data (Open ID, role ID, and text messages)	We use this information to facilitate your communications with other users.	Necessary to perform our contract with you to facilitate communication between users where you seek to use chat services.
Text chat data (Open ID, role ID, and text messages)	We use this information to filter profanity, abusive language or other uses of chat in violation of our End-user License Agreement.	It is in our legitimate interest to ensure the integrity of the Game and protect users from prohibited conduct.
Real-time voice chat data: voice data	We use this information to provide real-time audio chat functionality to facilitate your communications with other users.	Necessary to perform our contract with you to provide chat services in-Game where you seek to use chat services.
Voice message data: voice message	We use this information to provide the following functionalities to facilitate your communications with other users: ·       audio messaging functionality ·       speech-to-text functionality ·       voice message text translation services	Necessary to perform our contract with you to provide chat services in-Game where you seek to use chat services.
Voice chat and message data (other data): log file and reporting data (Open ID, room ID, SDK version, GME chat room status, packet loss rate, other log specific code such as API calling sequence and tracking logs) and device information (device OS version, device manufacturer, RAM, system time, device model, device name, CPU model, network type, IP address)	We use this information to: ·       troubleshoot, such as to address crashes and other issues; and ·       ensure consistent service quality.	Necessary to perform our contract with you to provide chat services in-game where you seek to use chat services. It is in our legitimate interest to use this information to be able to troubleshoot these features.
Transaction information: For purchases via the mobile version (in-app): Open ID, role ID, country, CPU model, device model, currency, SDK version, application version, network type, IDFV and amount. For purchases via the PC version: Items purchased, purchase price, time, date, currency, order ID, Open ID, role ID, country, game account balance and purchase history.	We use this information to process any payments you make within the Game (including for any in-game currency or subscription plan) and maintain a record of your transaction history.	Necessary to perform our contract with you to facilitate your payment and provide you with details of your transactions.
Customer service (game data): Open ID, role ID, and any information you choose to provide, including operating system, area ID, game server ID, zone ID, username, character ID, level of character, remaining balance, account status, name of the Game, account binding status, registration time, latest login time, player type (whether new player or not)	We use this information to: ·       provide troubleshooting, such as addressing and remediating technical issues and bugs; and ·       improve our services.	Necessary to perform our contract with you to provide and support the Game services. It is in our legitimate interest to use this information to improve our services.
Customer service (general data): ·       Via app: name, Open ID, device ID, application version, battery level, wifi strength, free space on phone, network type, iOS version, platform, network type, carrier, country code, and photo (optional) ·       Via website: name, Open ID, device ID, email address (optional) ·       Via email: name, email address ·       Details of ticket, complaint and handling. You also have the option of providing the following information to illustrate any errors: o   For mobile version: Open ID, channel ID, application identifier, application version, application name, OS version, platform, country code, language, SDK version, carrier, network type, device model, battery level, battery status, total space on device, free space on device, capacity and any other information you choose to provide o   For PC version: Open ID, channel ID, application identifier, application version, application name, OS version, total ROM, platform, country code, language, SDK version, network type, device model and any other information you choose to provide	We use this information to provide you with customer service support, whether in-app or via email, in accordance with your request, including to: ·       address any questions, requests or complaints; ·       provide troubleshooting, such as addressing and remediating technical issues and bugs; and ·       improve our services.	Necessary to perform our contract with you to provide and support the Game services. It is in our legitimate interest to use this information to improve our services.
Profanity filtering information: log data of SDK (including packet records of SDK, IP information of server).	We use this information to filter profanity, abusive language or other uses of chat in violation of our End-user License Agreement.	It is in our legitimate interest to ensure the integrity of the Game and protect users from prohibited conduct.
Anti-cheating information: User account information (account ID, character ID, nickname, server, channel), hardware information and identifiers, system information, game- and system-related files and memory, information about running processes, drivers and other executable code, how you interact with the game, screenshots of game window and of windows covering the game window	We use this information to: ·       prevent and detect cheating or other conduct that may compromise the integrity of the Game or otherwise violate our terms; and ·       ensure that our monitoring algorithms keep up with circumvention techniques.	It is in our legitimate interests to use this information to protect the fairness and integrity of the Game.
Suspected cheater list information: player ID, current status (i.e. whether suspected of cheating or not) and anti-cheating information (see above) related to the suspicious behaviour observed.	We use this information to maintain a temporary list of suspected cheaters for the purpose of deciding of action should be taken.	It is in our legitimate interests to use this information to protect the fairness and integrity of the Game.
Ban list information: player ID, ban status (i.e. whether banned) and anti-cheating information (see above). related to the suspicious behavior observed.	We use this information to maintain a list of players who are banned from the Game.	It is in our legitimate interests to use this information to protect the fairness and integrity of the Game.
Push notification information (only applicable to mobile version): device token and Firebase Cloud Messaging token	We use this information to send you notifications about game events, updates or other information.	Necessary to perform our contract with you to notify you about announcements, updates or information relating to the Game.
Marketing data (only applicable to mobile version): ·       Collected via Adjust: your technical data including pseudonoymized (hashed) IP address, mobile identifiers (IDFA and Google Advertising ID) and engagement information ·       Collected via Facebook: your contact information (for matching purposes only) and event data (information about you and the actions that you take in relation to the Game services) ·       Collected via Firebase: your app-instance ID, user device dimensions and in-app events, user information ·       Collected via AppsFlyer: your technical information, technical identifiers (IP address, user agent, IDFA, Google Advertising ID, and Open ID) and information regarding your engagement with our advertising campaigns	If you click on a link or interact with content that advertises the Game, we store this information and that advertisement and certain marketing analytics data with your profile in order to measure the performance of our advertisements.	It is in our legitimate interest to use this information to monitor the success of our advertising and marketing programs.
Game analytics information: For mobile version: ·       user region: country, province, city, carrier ID, region, IP address ·       device information: application version, application ID, battery information, WiFi strength, available space, network type, OS version, OS name, carrier, country code, device language, device resolution, brand, manufacturer, device model, total RAM, total ROM, CPU information, graphics processing unit information, graphics card driver version number, game frame information, mobile signal strength, network round trip time, network bytes received/sent, login step event information. XWID, network delay, packet loss rate and number of Android apps For PC version: ·       user region: country, province, city, carrier ID, region and IP address ·       device information: CPU name, CPU core, CPU frequency, graphics processing unit name, total RAM, total ROM, device model, device brand, screen width, screen height, OS type, OS version, SDK version and network type	We use this information for general game analytics to review and improve game performance.	It is in our legitimate interests to improve the Game.
Sharing to social media platform information: user sharing behavior (time, share channel, UID), in-game image generated based on your game data	We use this information to allow you to share content to social media platforms.	Necessary to perform our contract with you to to enable sharing of content to social media platforms.
Crash-related information: ·       For mobile version: device information (device name, device model, phone memory, CPU usage rate, CPU model, device system version, device brand, device manufacturer, total ROM, total RAM, device language, CPU architecture, whether root, remaining external SD card space, remaining memory, whether it is running in the simulator, running process information, APN, system time, battery status), process name, network type, SDK information (version number), application information (package name and version), network-signal-related data ·       For PC version: device information (CPU name, CPU core, CPU frequency, graphics processing unit name, total RAM, total ROM, device model, device brand, OS type, OS version), process name, network type, SDK information (version number), application information (package name and version), network-signal-related data	We use this information to collect crash-related information when crashes occur to locate and solve crashes.	It is in our legitimate interest to use this information to improve our services.
Validation information: Open ID, token, region, nickname, user status	We use this information to ensure the account registration process complies with this Privacy Policy.	Necessary to perform our contract with you to provide the Game.
Account deletion information: email address, device language, Open ID, user token, and any other information we may reasonably require to be able to delete your account.	We use this information to facilitate the deletion of your account upon your request.	Necessary to perform our contract with you to support the Game.

3.            How We Store and Share Your Personal Information

Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Game in Singapore, the United States, Brazil, Japan and Germany. The servers applicable to your use of the Game will depend upon your location or selection. We also have support, engineering and other teams who may support the Game, including from Singapore.

 

For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent first or taking into account adequacy assessments.

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

·       Third parties that provide services in support of the Game, including providers of services that process information identified in this policy for the purpose of providing the Game, including providers of cloud services (Amazon Web Services and Google Cloud Platform) that process information identified in this policy on their servers in the United States and Brazil (Amazon Web Services and Google Cloud Platform), Germany (Amazon Web Services), Singapore (Amazon Web Services) and a customer service provider (AIHelp) that processes customer service data identified in this policy on its servers in the United States, a push notification service provider (Firebase) that processes information on its servers in the United States for the purposes of notifying users of game events or updates, a speech-to-text and translation service provider (Google Cloud Platform) that processes chat data on its servers in the United States for the purpose of supporting chat services and third party SDKs (Adjust, Facebook, Firebase and AppsFlyer) that process marketing information identified in this Privacy Policy on their servers in Belgium (AppsFlyer), Germany (Adjust), Ireland (AppsFlyer), the Netherlands (Adjust) and the United States (Adjust, Facebook, Firebase) for the purpose of providing of assisting us with acquiring users for the Game. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game (i.e., for the purpose(s) described above).

·       Companies within our corporate group who process your personal information for the purpose of providing the Game to you or to otherwise deliver the best possible experience (such as to conduct surveys relating to the Game or to process payments).  All such group companies may only use your personal information in accordance with this Privacy Policy.

• Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
• Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
• enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
• A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

4.            The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Game or otherwise via the Internet; any transmission is at your own risk.

 

5.            Data Retention 

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
Guest log-in information Level Infinite Account log-in information Third party platform log-in information (Open ID) Open ID (Game data) Gameplay statistics IP Address Game log information Text chat data (only Open ID and role ID) Transaction information Sharing to social media platform information (user sharing behavior) Marketing data (collected via Adjust, Facebook, Firebase and AppsFlyer) Validation information (Open ID, user status and region)	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Third party platform log-in information (data other than Open ID)	Stored for 30 days from the day you last log in.
Customer service (general data)	Stored for 2 years, unless you request to delete your data, upon which such data will be deleted within 30 days.
Survey information	Stored for 3 months, unless you request to delete your Game account or data, upon which such data will be deleted within 30 days.
Events-related information	Stored only for the duration necessary to conduct the event including for the duration necessary to dispatch gifts or prizes and confirm their receipt.
Text chat data (public text message)	Stored for 30 days.
Text chat data (private text message) Real-time voice chat data Customer service (game data) Push notification information Sharing to social media platform information (image generated based on game data)	Not stored.
Voice message data Voice chat and message data (other data) Profanity filtering information	Stored for 90 days, unless you request to delete your Game account or data, upon which such data will be deleted within 30 days.
Game analytics information	Stored for 7 days.
Anti-cheating information	Not stored and only momentarily processed to prevent and detect cheating or other suspicious conduct. Stored for 14 days to ensure that our monitoring algorithms keep up with circumvention techniques.
Suspected cheater list information	Stored for 14 days.
Ban list information	Player ID and ban status: For the period of the ban or appeal. Anti-cheating information: Stored for the duration of the ban or 60 days from addition to the ban list, whichever is shorter.
Crash-related information Validation information (token, nickname)	Stored for 30 days.
Account deletion information	Stored for 30 days (i.e. the cooling-off period) after you request to delete your Game account.

 

6.            Your Rights

Some jurisdictions’ laws grant specific rights to users of the Game. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.

Access

You may have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account.

Portability

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

Correction

You may have the right to correct personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account.

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Game account. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Restriction of Processing to Storage Only

You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us using our online form for submitting data privacy related request and question at https://dsar.toweroffantasy-global.com/tchk?id=tof or using the contact details set out below, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us using our online form for submitting data privacy related request and question at https://dsar.toweroffantasy-global.com/tchk?id=tof. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Game for maintenance, or security, privacy or administrative-related communications). These are essential system and Game-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.

7.            Contact

Please get in touch with us if you have any questions.

You can reach us using our online form for submitting data privacy related request and question at https://dsar.toweroffantasy-global.com/tchk?id=tof.

For any questions not covered by the form, please email: dpo@toweroffantasy-global.com.

Mailing Address:

Tencent International Privacy & Data Protection Centre

30 Raffles Place #19-01

Singapore 048622

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

8.            Changes

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

9.            Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.

INFORMATION FOR PARENTS

Before your child can use Tower of Fantasy (the “Game”), you will need to provide your consent to approve your child’s account set-up and the processing of their personal information.

 

What personal information does the Game process?

 

Tower of Fantasy is a PC and mobile game.

 

If your child successfully signs up to the Game, this will result in the collection and sharing of certain personal information, including:

 

• account registration information such as nickname, language, region and profile picture;
• device information (including IP address and device identifiers) which is used to register each account, maintain the game environment, ensure optimal performance and security, and troubleshoot bugs;
• Identifier for Vendors (IDFV)/Identifier for Advertisers (IDFA)/Google Advertising ID, which is used solely to manage our promotion campaigns (there is no advertising within the Game);
• game data, log data and gameplay statistics (to provide the Game and save game progress);
• survey responses (if they choose to participate in game feedback surveys from time to time); and
• customer support information (if they contact customer support).

 

You can review our Privacy Policy for more details on what personal information we collect and how we use and process the information.

 

Does the Game process personal information differently for children?

 

Yes. In some jurisdictions children will not be able to access certain features – such as in-game free text and audio chats.

 

Why is my consent required?

 

Certain jurisdictions require or recommend the consent of a parent or legal guardian before their child can sign up to a game such as Tower of Fantasy, where personal information will be processed. If you do not consent, or withdraw your consent, we will immediately delete any personal information collected up to that point.

 

What method(s) can I use to verify my child’s account?

 

In some jurisdictions, including the United States, we ask for date of birth at registration. We will not allow a child to sign-up without first obtaining verifiable consent from that child’s parent or legal guardian. As part of this, we need to verify that you are an adult capable of providing such consent. To do this, we charge or authorize a small amount to a credit card. This process is handled by specify name of third party payment processor. We do not process your credit card information – only the third party payment processor collects credit card information. The credit card information is not retained for any reason, including future purchases or connected to in-app payment functions (if any) in the game.

 

What if there are changes to the Game in the future?

 

If we make any changes to the way their personal information is processed, we will notify you of those changes. You must consent to those changes before your child’s personal information will be processed for that new purpose.

 

Will you retain my personal information?

 

We will keep a record of your email address so that we can notify you of any changes to the processing of your child’s personal information, and so that we know you are a parent or legal guardian of a player when you contact us. As mentioned above, your credit card information is not processed by us, but instead only processed by a third party payment processor. We do not have access to your credit card information.

 

What if I do not consent?

 

If you do not consent (including by providing your credit card details for verification) then your contact information will be deleted.

 

How do I withdraw my consent or delete my child’s account?

You can withdraw your consent or delete your child’s account by submitting a request through our online form for data privacy related request and question at https://dsar.toweroffantasy-global.com/tchk?id=tof. You can also request a copy of your child’s personal information at any time using this form.

 

Our Representatives in Certain Jurisdictions

Jurisdiction	Representative	Address	Contact details
EU	Proxima Beta Europe B.V.	Buitenveldertselaan 3-5 1082 VA Amsterdam	dpo@toweroffantasy-global.com
UK	Image Frame Investment (UK) Limited	Suite 1, 3rd Floor 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB	dpo@toweroffantasy-global.com
Serbia	Karanovic & Partners o.a.d. Beograd	Resavska 23, Belgrade, 11000, Serbia	local.representative@karanovicpartners.com
Thailand	Tencent (Thailand) Company Limited	T-One Building, Bangkok, Thailand	dpo@toweroffantasy-global.com
Turkey	Özdağıstanli Ekici Avukatlık Ortaklığı.	Varyap Meridian Grand Tower ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul Turkey Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as user conduct, bans, investigations, civil or criminal complaints.	turkeydatarep_proximabeta@iptech-legal.com

 

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Game, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Algeria

By using the Game, you give your consent to the collection, storage, treatment and use of your personal information, and transfer of your personal information to third parties or our affiliates to help us deliver the Game, in each case location in the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

Argentina

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar). While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing your personal information and by using the Game, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Australia

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients. You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to correct any of your personal information we hold that is inaccurate.

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Game. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Game, including social media integration and in-Game purchases.

 

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).

Bangladesh

By acknowledging the Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by the Privacy Policy. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

Brazil

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us as set out in Section 8 (Contact). This may affect our provision of the Game to you.

 

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

 

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

• Identifiers, such as your name as it appears on your third-party platform profile, username, Open ID, player ID, user ID, role ID, account ID, character ID, user token, IDFV, IDFA, Google Advertising ID, XWID, IP address, email address, and username. This information is collected directly from you and your device and from third-party platforms if you choose to sign up using a third-party account.
• Geolocation data such as your region location provided by you or region derived from your IP address when you set up your account. This information is collected directly from you or your device.
• Internet or other electronic network activity information, such as your information regarding your use of the Game, including level, gameplay statistics, date and time stamps of actions, log-in and how you interact with the Game and advertisements for the Game and other device and network information as described in the main Privacy Policy. This information is collected directly from you and your device.
• Commercial information about any transactions within the Game such as what products were purchased and how much they cost. This information is collected directly from you and your device and the Google Play or Apple iOS store.
• Audio and visual information such as your third-party platform profile picture, photos shared in the Game, and voice chat and messages. This information is collected directly from you and from third-party platforms if you choose to sign up using a third-party account.
• Other information described in subdivision (e) of Section 1798.80, including information about your gender or age range. This information is collected directly from you in the context of being our consumer.

 

We collect your personal information for the following purposes:

• To provide you with the Game, maintain your account, provide customer service, process payments, provide push notifications of game events and updates, and deliver voice and text chat and voice messages or otherwise facilitate communications between users.
• To process surveys.
• To conduct events such as giveaways, draws and contests and similar events related to the Game.
• To improve our services, including the functionality of the Game.
• For security and anti-cheating purposes, including to prevent and detect cheating and other activities which may compromise the integrity of the Game.
• To address and remediate technical issues and bugs.
• To monitor our marketing initiatives.
• To comply with our legal obligations and enforce our legal rights.

 

For additional information about what each type of personal information is used for, see Section 3 (How We Process Your Personal Information).

 

We disclose personal information to the following types of entities:

• Other companies within our corporate group who process your personal information in order to operate the Game.
• Other companies that provide services on our behalf in support of the Game and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
• Regulators, judicial authorities and law enforcement agencies
• Entities that acquire all or substantially all of our business.

 

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

 

Rights under the CCPA:

 

If you are a California resident, you have the right to:

• Request we disclose to you free of charge the following information covering the 12 months preceding your request:
• the categories of personal information about you that we collected;
• the categories of sources from which the personal information was collected;
• the purpose for collecting personal information about you;
• the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
• the specific pieces of personal information we collected about you;
• Request we delete personal information we collected from you, unless CCPA recognises an exception; and
• Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.  

 

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

 

How to Exercise Your Rights

 

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 8 (Contact).

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as specified in Section 8 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

Colombia

Your authorization to process personal information for the Game may be expressed (i) in writing, (ii) orally or (iii) through unequivocal conduct that allows us to reasonably conclude that your authorization has been granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

 

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information. You can contact us to exercise any of these rights, using the information specified in Section 8 (Contact)

Egypt

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

 

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

 

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

 

France

Instructions for the processing of your personal data after your death. You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.

 

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

 

When you wish to make such instructions, please contact us as set out in Section 8 (Contact).

India

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

 

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us as set out in Section 8 (Contact). Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.

Indonesia

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

In the event we fail to maintain the confidentiality of your personal information in the Game, we will notify you through the contact information provided by you or via the Game, to the extent required by local laws and regulations.

If you fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen (14) days of the date the relevant amended version of this Privacy Policy is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy. However, you may stop using or accessing our Game by unsubscribing or ceasing your use of the Game at any time, if you cease to agree with the amended  Privacy Policy.

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

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

By clicking “accept”, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

 

The categories of personal information specified in to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information) may include "special care-required personal information" (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

 

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us as set out in Section 8 (Contact).

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws) and storage of your personal information as described in this Privacy Policy.

Kuwait

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Malaysia

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Game, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

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

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However, this may affect our provision of the Game to you.

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

• Our data protection officer, responsible for the management and safety of your personal information
• Telephone: +603-22872388
• Email: as set out in Section 8 (Contact)

Mexico

Some of the purposes of processing specified in Section 3 (How We Process Your Personal Information) are voluntary, which may include to show you personalised recommendations or advertising.

In general, we do not require your consent to carry out the transfers detailed in Section 4 (How We Store and Share Your Personal Information). In any case, by using the Game and providing us with your personal data, you agree to the data transfers detailed therein that require your consent.

To understand more about and exercise your rights, as well as the applicable means, procedures and requirements to exercise any of your rights as specified in Section 8 (Contact).

You can register with the Public Registry to Avoid Advertising (‘REPEP’) (REPEP (profeco.gob.mx) ) to refuse to receive advertising to your phone number.

Morocco

We collect information for purposes strictly necessary for the proper use of the Game. By accepting this Privacy Policy, you explicitly accept that your personal data may be subject to processing by the Game.

 

Kindly note:

 

• the identity of the Data Controller is set out at the beginning of this Privacy Policy
• the purposes of processing personal data are are set out in Section 3 (How We Process Your Personal Information)
• recipients or categories of recipients are set out in Section 4 (How We Store and Share Your Personal Information)
• whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to Section 3 (How We Process Your Personal Information) and Section 7 (Your Rights)

New Zealand

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

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

If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Peru

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, pursuant to the Personal Data Protection Law (the “Law”). You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

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

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

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

• Data Protection Team, responsible for the management and safety of your personal information
• Contact: as set out in Section 8 (Contact)

Philippines

You are entitled to the following rights:

• Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
• Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
• Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
• Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
• Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

By consenting to this Privacy Policy, you consent to us:

·       collecting and processing your personal information as described in Section 3 (How We Process Your Personal Information);

·       sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and

·       transferring or storing your personal information in destinations outside the Philippines as described in Section 4 (How We Store and Share Your Personal Information)

Qatar

If you are using the Game in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Russia

The Game is not directed at Russian users or Russian market and, in particular, is not available in the Russian language. However, if you happen to be using the Game in Russia, this section “Russia” applies to you. By using the Game you consent to:

• for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations, the processing of your information in accordance with this Privacy Policy; if legitimate interests, optimisation of the Game or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law);
• the cross-border transfer of your information to any country where we have databases or affiliates, in particular as described in Section 4 (How We Store and Share Your Personal Information);
• for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this Privacy Policy; and
• for the purposes of Federal Law “On Marketing/Advertising”, that we may share advertising/marketing communications with you, unless you have opted-out from such communications.

 

We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Game after the notification.

As regards the representative for Russia, you can contact us as specified in Section 8 (Contact). Please include the word “Russia” in the subject line of your email.

Serbia

Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.

• Name: Karanovic & Partners o.a.d. Beograd
• Address: Resavska 23, Belgrade, 11000, Serbia
• Telephone Number: +381 11 3094 200
• E-mail: local.representative@karanovicpartners.com

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 4 (How We Store and Share Your Personal Information).

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

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 8 (Contact).

South Africa

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

Sri Lanka

By clicking “accept”, you consent to the Privacy Policy and permit the collection, use and disclosure of your personal information. However, if you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

Thailand

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us as set out in Section 8 (Contact).

Turkey

You have legal rights, which are set forth in Article 11 of the Turkish Law on Personal Data Protection Law (“DPL”), in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

 

 

• learn whether or not your personal data has been processed;
• request information about processing if your personal data has been processed;
• learn the purpose of processing of your personal data and whether they have been used accordingly;
• know the third parties in the country or abroad to whom personal data has been transferred;
• request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
• request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
• object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems, and
• demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

 

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

 

Identity of the overseas recipient	Location of the recipient (or as otherwise stated in the recipient’s privacy policy)	Purposes of use of Personal Information by the recipient	Items of Personal Information to be provided
Amazon Web Services	United States unless otherwise described in the service provider’s privacy policy	Processing and/or storage of personal information	Customer service data, validation information, account deletion information, game analytics information, sharing to social media platform information, guest log-in information, email log-in information, third party platform log-in information (for log-in via third-party platform accounts), guest log-in information, voice message data, voice chat and message data (other data)
	Germany, Singapore		Anti-cheating information, uspected cheater list information and ban list information
AIHelp	United States unless otherwise described in the service provider’s privacy policy	Provision of customer support services	Customer service data
Aceville Pte Ltd	Singapore	Processing and/or storage of personal information	If you select the Singapore server: email log-in information, Open ID (game data), gameplay statistics, IP address, game log information text chat data (Open ID, role ID, and text messages), survey information, crash-related information, sharing to social media platform information, transaction information, profanity filtering information
	Japan		If you select the Japan server: email log-in information, Open ID (game data), gameplay statistics, IP address, game log information text chat data (Open ID, role ID, and text messages), survey information, crash-related information, sharing to social media platform information, transaction information
	Brazil		Sharing to social media platform information, IP address, transaction information
ServiceNow	United States	Processing and/or storage of personal information	Email address, account information such as Open ID, user token and any information we reasonably need to ascertain the account belongs to you.
Tencent Cloud LLC	United States	Processing and/or storage of personal information	Sharing to social media platform information, IP address, transaction information, profanity filtering information
Tencent Cloud Europe B.V.	Germany	Processing and/or storage of personal information	text chat data (Open ID, role ID, and text messages), sharing to social media platform information, IP address, transaction information
Google Cloud Platform	United States unless otherwise described in the service provider’s privacy policy	Processing and/or storage of personal information and provision of speech-to-text and translation services for in-game communications	If you select the North or South America server: email log-in information, Open ID (game data), gameplay statistics, IP address, game log information text chat data (Open ID, role ID, and text messages), survey information, crash-related information real-time voice chat data, voice message data
Google Firebase	United States unless otherwise described in the service provider’s privacy policy	Provision of push notifications and analysis of marketing efficiency	Push notification information (applicable to mobile version only) and marketing data (collected via Firebase) (applicable to mobile version only).
Facebook	United States unless otherwise described in the service provider’s privacy policy	Analysis of marketing efficiency	Marketing data (via Facebook) (applicable to mobile version only)
AppsFlyer Ltd.	Dublin, Ireland hosted by AWS and in St. Ghislain, Belgium hosted by Google Cloud	Analysis of marketing efficiency	Marketing data (via AppsFlyer) (applicable to mobile version only)
Adjust GmbH	Germany, Netherlands, and the United States	Analysis of marketing efficiency	Marketing data (via Adjust) (applicable to mobile version only)

 

Ukraine

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries other than Ukraine, to the extent and for the purpose provided by this Privacy Policy.

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information, as described in the Privacy Policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

Vietnam

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

 

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

 

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