TOWER OF FANTASY – OFFICIAL GAME WEBSITE

PRIVACY POLICY

Last Updated: 17 June 2022

Welcome to the Tower of Fantasy Official Game Website!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the official game website (“Website”) for Tower of Fantasy, and sets out your choices and rights in relation to that information. Please read it carefully 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 use the Website. By using the Website, you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

This Website 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 this Website 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. Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Website. Cookies enable us to provide certain features and functionalities. For more information about our Cookies policy, click here.

2. Children

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

By children, we mean users under 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 details 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)
Game Updates or News
Email address	If you register your interest, we use this information to provide you with news or updates on Tower of Fantasy.	We collect this information with your consent.

4. How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to allow you to use the Website, 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 Website are located in 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.

By clicking the button to proceed, you consent to the cross-border transfer of your information to any region where we have databases or affiliates and, in particular, to Singapore and the United States.

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 Website and CBT services, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Website and CBT services. 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 support of the Website and CBT services. 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.
• 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 Website 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
Email address (if you sign up for updates or news on Tower of Fantasy)	Stored for 6 months.

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 Website, 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.

The sub-section entitled “Game Updates or News” also apply to users that are located in Brazil, Japan and the United States.

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 by contacting 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 or pursuant to our contract with you, 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 by contacting us at dpo@toweroffantasy-global.com.

Erasure

If there is any 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.

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). 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 may 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 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.

Game Updates or News

If you have subscribed to game updates or news, you may choose to stop receiving such information from us by contacting us at dpo@toweroffantasy-global.com.

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 Website, 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 email address and IP address. This information is collected directly from you and your device.
• Geolocation data such as your region derived from your IP address. This information is collected directly from your device.
• Other information described in subdivision (e) of Section 1798.80, including information about your device type, device model, gaming experience and game preference. This information is collected directly from you and your device in the context of being our consumer.

We collect your personal information for the following purposes:

• If you register for the CBT of Tower of Fantasy, to determine your region and eligibility.
• If you register for the CBT of Tower of Fantasy, to send you a link to the CBT of Tower of Fantasy if you are selected.
• If you register for the CBT of Tower of Fantasy, to better understand you and to improve Tower of Fantasy.
• To provide you with information and updates on Tower of Fantasy if you register your interest.

For additional information about what each type of personal information is used for, see the section “How We Use Your Personal Information” 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 support of the Website and CBT services.
• Other companies that provide services on our behalf in support of the Website and CBT services 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

If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, regarding your 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 use the Website.

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 region where we have databases or affiliates and, in particular, to Singapore 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