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 closed beta test (the “CBT”) of the mobile and PC game Tower of Fantasy (the “Game”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

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 services. By using the Game services, you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

This Game has been developed by Proxima Beta Pte. Limited (“we”, “us”, “our”).

For the purpose of data protection laws, the data controller of your personal information in relation to the CBT is Proxima Beta Pte. Limited. The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore 079903.

Our data protection officer can be contacted at dpo@toweroffantasy-global.com.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. You can contact us anytime at dpo@toweroffantasy-global.com.

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How We Use Your Personal Information” below.

The following is a high-level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party).

· Account registration information: You give us information about you when you set up an account to register for the CBT: (i) your email address, email verification code, language, region, username, password, IP address and Open ID if you register and log in with your email, or (ii) information we import from your connected social media account (Apple, Google Play, Facebook, Twitter and Line) if you register or log in via your social media account, including your name, user ID, nickname, user token, Open ID and your profile picture (if any). If you use standard Facebook Login, your actual account information will be imported. If you use Facebook Login for Gaming, dummy account information will be used. You also provide us with information when you set up your profile for the CBT.

· Survey Information: If you choose to participate in a survey about the Game services, you may be asked to provide certain personal information, such as your gender (optional), age range (optional), country or region of residency (optional), income information (optional), phone number (optional), email address (optional), nickname (optional) and any other content you choose to provide as part of the survey response. We will use your survey response for the purpose of improving the Game services. We will use IMUR Survey services for the Game. If you choose to participate in an in-game survey regarding the Game, we will redirect you to IMUR to take the survey and will only process your aggregated and anonymised survey responses once you complete the survey on IMUR Survey. The IMUR Survey privacy policy will apply to certain data processed in connection with your participation in any survey regarding the Game services. You can read more in the IMUR Survey privacy policy available at here.

2. Information about you generated as part of the CBT

We automatically collect certain data from you when you participate in the CBT, namely:

· Guest log-in information: Guest ID.

· Game data (including log information): Your Open ID, IP address, game log information and gameplay statistics (e.g. player level, in-game performance and virtual currency).

· Chat data: If you use text or audio chat service, we will process your Open ID, role ID, messages, device information and time stamps to deliver your messages to other users.

· Customer service information: Information collected when you communicate with customer service, when you give us reviews or feedback, or otherwise provide information to us.

· Security-related information: Open ID, network type, device information and application information.

· Crash-related information (Bugly): Device information, process name, network type, SDK information, application information, buried data reporting.

· Eligibility information: Open ID, token, region, nickname, email address.

· Account deletion information: Email address, device language, Open ID, user token.

· For the purposes of push notifications (only applicable to mobile version): Device toke, Firebase Cloud Messaging token, device dimensions and in-app events.

· In-app purchases: Open ID, role ID, country, device information (device model, IDFV, IP address, network type, network monitoring data, client exports IP) and other information (country currency, SDK version, application version).

· Game analytics information: User region and device information

· PC game launcher information: Email, verification code, region, username, password, IP address, Open ID

We automatically collect certain data from you via third-party SDKs when you use the mobile version of the Game services for analytics, profiling and user acquisition purposes, namely:

· Your Open ID, user ID, nickname, app-instance ID, user dimensions and in-app events.

· Your technical information, technical identifiers and information regarding your engagement with our advertising campaigns.

· Your contact information and event data (information about you and the actions that you take in relation to the Game services).

2. Children

Children must not use the Game services for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

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 in the table below.

Region in which the user is located	Minimum age of the user
Brazil	18
Indonesia	21
Japan	18
Thailand	20
United States	13

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 parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo@toweroffantasy-global.com and we will delete such information.

3. How We Use 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 the European Economic Area or the United Kingdom (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (only relevant if you are located in a Relevant Jurisdiction)
Information you provide to us (either directly or through a third party)
Email log-in information: email address, email verification code, language, region, username, password, IP address and Open ID	We use this information to create your account for the CBT in accordance with your request and to facilitate your logins.	Necessary to perform our contract with you to provide the CBT.
Social media information (if you choose to log in via your social media account with these networks): · Apple: Apple ID, nickname, profile picture, user token, Open ID · Standard Facebook Login: name (as it appears on Facebook), Facebook UID, profile picture, user token, Open ID · Facebook Login for Gaming: dummy name, dummy Facebook UID, dummy profile picture, dummy user token, dummy Open ID · Google Play: user ID, nickname, profile picture, user token, Open ID · Twitter: user ID, nickname, profile picture, user token, Open ID Line: user ID, nickname, profile picture, user token, Open ID	We use this information to create your account for the CBT in accordance with your request and to facilitate your logins.	Necessary to perform our contract with you to provide the CBT.
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.
Information generated as part of the CBT
Guest log-in information: Guest ID	We use this information to create your account for the CBT in accordance with your request and to facilitate your logins.	Necessary to perform our contract with you to provide the CBT.
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 CBT.
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 CBT 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.	Necessary to perform our contract with you to provide the CBT.
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, GPU information, RAM, client exports IP, phone memory, login channel ID, operator name, network type, signal strength, and buried data reporting 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, GPU information, RAM, client exports IP, disk memory, login channel ID, network type and buried data reporting	We use this information: · to improve our services, including the functionality of the Game; · for security and verification purposes; and · to maintain a record of log-in and actions of the user account.	Necessary to perform our contract with you to provide the CBT and to document and save details of your use for future gameplay.
Chat data: Open ID, role ID, text and/or audio messages, device information and time stamps	We use this information to: · facilitate your communications with other users. · filter abusive language or other uses of chat in violation of our End-user License Agreement	Necessary to perform our contract with you to provide the chat services in-game. It is in our legitimate interest to ensure the integrity of the Game and protect users from prohibited conduct.
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, VIP level, 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: · improve our services; and · provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the Game 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, VIP level, diamonds number, pet number, unlocked level 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, VIP level, diamonds number, pet number, unlocked level and any other information you choose to provide	We use this information to: · improve our services; and · provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the Game services.
Security-related information: Open ID, network type, device information (including brand, CPU architecture, root status, unique identifier of ROM, mask resolution, system startup time, whether running in simulator, international coding and language, remaining memory, remaining built-in and external SD card space, installed APK information, running process information, host file, SD card application cache directory file name list) and application information (including package name, application version, startup time, process name)	We use this information to: · provide a fair environment; · solve crashes and optimize compatibility; · filter profanity; · detect use of plug-ins or other cheating behaviour; and · detect the existence of domain name hijacking.	It is in our legitimate interests to use this information to protect the integrity of the Game and improve its operation.
Analytics, profiling and user acquisition 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).	We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements.	It is in our legitimate interest to use this information to monitor the success of our advertising and marketing programs.
Crash-related information (Bugly): · 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), buried data reporting · For PC version: device information (CPU name, CPU core, CPU frequency, GPU (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), buried data reporting	We use this information to: · collect crash-related information when crashes occur; and · improve our services.	Necessary to perform our contract with you to provide and improve our services.
Eligibility information: Open ID, token, region, nickname, email address	We use this information to verify your eligibility to participate in the CBT.	Necessary to perform our contract with you to provide and support the CBT.
Account deletion information: email address, device language, Open ID, user token	We use this information to facilitate the deletion of your account upon your request.	Necessary to perform our contract with you to support the CBT.
Push notifications (only applicable to mobile version): device token, Firebase Cloud Messaging token, device dimensions and in-app events	We use this information to send you notifications about game events and updates.	It is in our legitimate interest to send you notifications about game events and updates.
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, GPU information, game frame information, mobile signal strength, network round trip time, network bytes received/sent, login step event information For PC version: · user region: country, province, city, carrier ID, region, IP address · device information: CPU name, CPU core, CPU frequency, GPU name, total RAM, total ROM, device model, device brand, screen width, screen height, OS type, OS version, SDK version, network type	We use this information for general game analytics to review and improve game performance.	It is in our legitimate interests to conduct app analytics to improve the Game.
Analytics and profiling data (only applicable to mobile version): · Collected via Firebase: your app-instance ID, user dimensions and in-app events. · 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.	We use this information to monitor your participation in the SL and engagement with our advertising campaigns.	It is in our legitimate interest to use this information to monitor the success of our advertising and marketing programs.
In-app purchases: Open ID, role ID, country, device information (device model, IDFV, IP address, network type, network monitoring data, client exports IP) and other information (country currency, SDK version, application version)	We use this information in order to process any payments you make within the Game.	Necessary to perform our contract with you to facilitate your payment.
PC game launcher information: Email, verification code, region, username, password, IP address, Open ID	We use this information to create your account for the CBT in accordance with your request and to facilitate your login when you use a PC device.	Necessary to perform our contract with you to provide the CBT.

4. How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide you with the Game services, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers for the CBT are located in Singapore, Brazil and the United States.

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore.

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 CBT, including providers of cloud services that process information identified in this policy on their servers in the United States for the purpose of providing the Game services, customer service providers that process information identified in this policy on their servers in the United States for the purpose of providing customer support services, and providers of analytics, profiling and user acquisition services that process information identified in this Privacy Policy on their servers in Brazil and the United States for the purpose of providing of assisting us with acquiring users for the Game. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

· Companies within our corporate group who process your personal information in order to operate the CBT and conduct surveys for us. All related group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also 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 (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.

5. The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. 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 services or otherwise via the Internet; any transmission is at your own risk.

6. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. 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	Stored for the lifetime of your participation in the CBT unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. If you do not request for account or data deletion, stored and deleted within 30 days after the end of the CBT.
Email log-in information	Stored for the lifetime of your participation in the CBT unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. If you do not request for account or data deletion, stored and deleted within 30 days after the end of the CBT.
Social media information	Stored for the lifetime of your participation in the CBT unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. If you do not request for account or data deletion, stored and deleted within 30 days after the end of the CBT.
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.
Open ID (Game data) Gameplay statistics IP Address Game log information	Stored for the lifetime of your participation in the CBT unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. If you do not request for account or data deletion, stored and deleted within 30 days after the end of the CBT.
Text chat data	Not stored.
Chat data (Open ID, role ID and time stamps)	Stored for the lifetime of your participation in the CBT unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. If you do not request for account or data deletion, stored and deleted within 30 days after the end of the CBT.
Customer service (game data)	Not stored.
Customer service (general data)	Stored for the lifetime of your participation in the CBT unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. If you do not request for account or data deletion, stored and deleted within 30 days after the end of the CBT.
Security-related information	Stored for the lifetime of your participation in the CBT unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. If you do not request for account or data deletion, stored and deleted within 30 days after the end of the CBT.
Analytics, profiling and user acquisition data (collected via Adjust and Facebook)	Stored for the lifetime of your participation in the CBT unless you request to delete your Game account or data, upon which such data will deleted within 30 days. If you do not request for account or data deletion, stored and deleted within 30 days after the end of the CBT.
Push notification information	Stored for the lifetime of your participation in the CBT unless you request to delete your Game account or data, upon which such data will deleted within 30 days. If you do not request for account or data deletion, stored and deleted within 30 days after the end of the CBT.
In-app purchase information	Stored for the lifetime of your participation in the CBT unless you request to delete your Game account or data, upon which such data will deleted within 30 days. If you do not request for account or data deletion, stored and deleted within 30 days after the end of the CBT.
Crash-related information (Bugly)	Stored for 30 days.
Eligibility information	Stored for 30 days.
PC game launcher information	Stored for 30 days.
Account deletion information	Stored for 30 days and deleted upon the expiry of the cooling-off period.
Game analytics information	Stored for 7 days.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

7. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Game services, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in the Relevant Jurisdictions. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at dpo@toweroffantasy-global.com.

Access

You 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. If you believe we hold any other personal information about you, please contact us at dpo@toweroffantasy-global.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., username), as described above in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo@toweroffantasy-global.com.

Erasure

You can delete your account, or remove certain personal information, by logging into your Game account. If there is any other personal information you believe we process that you would like us to erase, please contact us at dpo@toweroffantasy-global.com.

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. Where you have requested that we erase personal information that has been made available publicly on the Game and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to 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). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. If you wish to do so, we will consider your request if you contact us at dpo@toweroffantasy-global.com.

Consent Withdrawal

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 at dpo@toweroffantasy-global.com. 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.

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 services for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

8. Contact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo@toweroffantasy-global.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo@toweroffantasy-global.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the region in which you live or work where you think we have infringed data protection laws.

9. Changes

If we make any material changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

10. 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.

SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS

Some jurisdictions’ laws contain additional terms for users of the Game services, 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.

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, username, Open ID, Game ID, role ID, character ID, IP address, device ID, IDFA, Google Advertising ID, device name, user token, phone number, email and address. This information is collected directly from you and your device.
Internet or other electronic network activity information, such as your information regarding your use of the Game, including level, performance, date and time stamps of actions, log-in and clickstream data and other device Information as described in the main Privacy Policy. This information is collected directly from you and your device.
Geolocation data such as your region location when you set up your profile and choose to provide this information for the Game. This information is collected directly from you.
Professional or employment-related information such as your profession if you choose to provide it in a survey. This information is collected directly from you.
Other information described in subdivision (e) of Section 1798.80, including information about your gender or age. 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, deliver text chat messages and provide a safe Game environment.
To process surveys.
To improve our services, including the functionality of the Game.
For security and verification purposes, including to prevent and detect fraudulent activity.
To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.

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 and support 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 at dpo@toweroffantasy-global.com.

Japan

Minimum Age

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 services.

Consent to transfer to third parties

By clicking the button to proceed, 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, affiliates or service providers and, in particular, to Singapore, Brazil and the United States.

Your Rights

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 at dpo@toweroffantasy-global.com.

Indonesia

Consent

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.

Parental and Guardian Consent

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 services.

Data Subject Rights

You have the right to access your personal information stored in our Game services from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

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

Data Retention

We will retain your personal information in line with legal requirements.

Notification to Amendment of this Privacy Policy

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 services at any time, if you cease to agree with the amended Privacy Policy.

Data Accuracy and Third Party Consent

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, 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).

Thailand

By clicking “acknowledge”, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the Game services.

You may request us to access, to correct, to delete, 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, and you may object to certain processing of your personal information and/or withdraw consent you previously provided to us for certain processing activities, 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 at dpo@toweroffantasy-global.com.

We will give you notice by email of any material changes to this Privacy Policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

Brazil

This section applies to users located in Brazil:

Consent Revocation

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 dpo@toweroffantasy-global.com. This may affect our provision of the Service to you.

Parental and Guardian Consent

If you are under the age of 18, you should not use the Service for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.

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.