What information do we need to be able to provide the Game Services?

In relation to the Game:

· If you register an account to use the Game then we will need some information from you to set this up. This includes your username, email address, and phone number. We will generate an Open ID, which is an internal ID for your account.

· If you choose to set up your profile using a social media account, we collect information provided by your social media account service provider to automatically generate your profile, including name and contact email.

· If you choose to use the Cloud version of the Game, we will collect additional information from you for the purposes of providing this service.

· To maintain the smooth operation of the Game (which includes activities such as from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information (such as IP address, connection information, device specifications, as well as app- and OS-generated identifiers).

· If you wish to participate in our surveys, we will process survey information and device data, such as email address, geographic (country or region) location, IP address and browser version, with your consent to better understand our users and to improve the Game. 

· If you need to get in touch with us, we will retain some information (such as your player identity information, device information and interactions with our help services) so that we can review and respond to your concerns.

In relation to the Website:

· If you register to receive updates on the development of the Game, and participate in promotional activities (e.g. the raffle feature, Dragon Raid Bounty and Official launch server first kill), on the Website, then you will need to register for the LEVEL INFINITE PASS, for which you would need to provide your user name, email address, phone number, and country of residence.

· To maintain the smooth operation of the Website and perform statistics on page view and user view of the Website, we will process customary device and network information (such as IP address).

· If you access other features on the website, e.g. the promotional activities or the questionnaire or the Guild Zone, we may process additional information to provide you with the feature.

In relation to Taris Ranking:

· If you log in to your Game account or social media account to use Taris Ranking, we collect information provided by your social media account service provider, including name and contact email, to connect to your profile.

· To maintain operation of Taris Ranking, we will process your profile information, leaderboard highlights, game statistics, and performance data (such as your score and ranking within the Game).

In relation to the Twitch Drops Event:

· For you to participate in theTwitch Drops Event, we would require you to log in to your Twitch account and your LEVEL INFINITE PASS, where we collect information provided by your social media account service provider, including name and user ID from Twitch  and open ID from LEVEL INFINITE PASS, to connect to your profile

· We will process your list of characters for the Game after you log in to your Twitch account and your LEVEL INFINITE PASS account, to provide your Twitch Drops rewards to your chosen character.

In relation to the Top-up Rebates Event:

· To participate in the Top-Up Rebates Event, we would require  you to log in to your Game account or social media account, we collect information provided by your social media account service provider, including name and user ID and open ID, to connect to your profile.

· We will process your top-up and transaction details after you log in to your Game account or social media account to determine your rebates amount and items unlocked.

More Information.

How will we use your information?

· In relation to the Game: We use your information to set up your account, enable you to use the Game, customize your Game experience, enable interaction between users of the Game, save your progress, ensure the safe and secure operation of the Game, address bugs, optimise and improve the Game, protect users, resolve user queries, and allow us to get in touch with you.

· In relation to the Website: We use your information to enable you to participate in promotional activities for the Game on the Website, optimise and improve the Website, resolve user queries, provide you with updates of the Game, and provide you with Guild functions.

· In relation to Taris Ranking: We use your information to enable you to use Taris Ranking, provide you and other players with your score and profile, character information, your in-Game battle records (such as date and duration), zone information, and performance rankings.

· In relation to the Twitch Drops Event: We use your information to enable you to participate in the Twitch Drops Event to claim Twitch Drops rewards.

· In relation to the Top-Up Rebates Event: We use your information to enable you to participate in the Top-Up Rebates Event so that you can claim rebates as you top-up.

· We also use your information 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 analytics purposes as well as for facilitating purchases / in-Game transactions, and customer support).

· 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 Services (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 Services in Singapore, the United States, Brazil and Germany, which can be chosen by you. We also have support, engineering and other teams who may support the Game Services, including from Singapore, Hong Kong and the PRC.

· 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.

Region in which the user is located

Minimum age of the user

Algeria

19

Argentina

13

Australia

18

Bangladesh

18

Brazil

18

Cambodia

18

Canada

13

Colombia

18

European Economic Area

16

Indonesia

18

Kazakhstan

18

Malaysia

18

Mexico

18

Myanmar

18

New Zealand

16

Nigeria

13

Philippines

18

Serbia

15

Singapore

13

South Africa

18

Sri Lanka

18

Switzerland

14

Thailand

20

Türkiye

18

United Kingdom

13

United States

13

Personal Information

Use

Legal Basis (where applicable)

In relation to the Game

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

Account registration information: (if you choose to log in via your social media account, social media information will be collected)

· Facebook account login: user ID, nickname, profile picture, user token and open ID

· Google Play account login: user ID, nickname, profile picture, user token and open ID;

· Apple account login: user ID, nickname, profile picture, user token and Open ID;

· Steam account login: user ID, nickname, profile picture, user token and open ID;

· LEVEL INFINITE PASS account log-in information (if you choose to log-in via LEVEL INFINITE PASS account): email address, password, user ID, nickname, user token, open ID, country (see https://account.levelinfinite.com/privacypolicy.html); and

· Guest login: guest ID and Open ID. 

We use this information to create your account for the Game Services (or link your Game account to another account of an eligible platform) in accordance with your request.

Necessary to perform our contract with you to provide the Game.

Region location (manually selected by you)

We use this information to:

· set up your use of the Game on a regional server; and

· provide you with your geographic ranking.

Necessary to perform our contract with you to provide the Game.

Email address (for compliance purposes, i.e. verification of parental or guardian consent) 

If you are located in certain regions, we may ask you to provide an email address for the purpose of verifying parental or guardian consent to use the Game services if you are under the relevant minimum age.

Necessary to perform our contract with you to provide the Game.

Data Subject Request Ticket Information:

· Information of the data subject: Your country/region, alias or name, email address, user ID, information related to your Service account (such as in-Service screenshot(s), account registration date, login method and/or connected social media accounts, cash/token/points balance information), any other information necessary for identity verification or to respond to your request

· Information of the requestor (if different from the data subject): Name, email address, relationship with data subject, proof of identity, proof of data subject identity, requestor's authority, any other information necessary for identity verification or to respond to your request

· Communications with you relating to your data subject request ticket and any other information provided by you.

When you submit a data subject request ticket (or someone submits a request on your behalf), we collect this information to:

· verify your identity (and, if applicable, the requestor’s identity if different from the data subject); and

· evaluate, respond to, process, and communicate with you regarding your data subject request.

Necessary to comply with a legal obligation.

Survey information: gender, age or age range, email address, occupation, and 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, we may 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.

We use this information with your consent to better understand our users and to improve the Game.

We collect this information with your consent.

Information collected and generated as part of the Game

XWID: your XWID, which is generated by us

We use this information for app analytics and debugging.

It is in our legitimate interest to use this identifier for app analytics and debugging.

In-Game Notifications / Announcements Information: Open ID, device ID

We use this information to send you in-Game notifications and announcements relating to the Game.

We send you notifications about the Game with your consent.

Information in relation to Game optimization and improvement: 

· User ID (Open ID, UAID, XWID, Universally Unique Identifier, Android ID);

· User region (IP address, client exports IP, country, province, city);

· Device and operating system information (including carrier ID, device model, device brand, device resolution, device language, device manufacturer, device system version, screen width, screen height, screen resolution, CPU information, CPU core, CPU frequency, CPU usage rate, CPU architecture, GPU informtion, total ROM, system language, OS name, OS version, phone memory, battery status, battery information, remaining memory, system time, system startup time, operator information, system properties);

· Other technical information: session information (system start up time, APP crash stack information, error code, error message, SDK name, SDK version, request URL, response body, sequence ID, login channel ID stage, log, game ID, client source, session ID, event time, event name), network information (network type, WiFi status, WiFi strength, available space, network traffic, network round trip time, network bytes received/sent, mobile network code, country code, mobile signal strength, network delay), application information (bundle ID, application version, application package name, root status, packet lost rate, android app count), login/pay step event information, and buried data reporting.

We use this information to operate and provide the Game, including to:  

· review and analyze Game performance for optimization (including network connection and connection and access to server);

· fix bugs in the Game and resolve crashes and other issues;

· manage Game resources and version updates;

· locate and resolve crash issues; and

· improve our services including the functionality of the Game.

It is in our legitimate interest to use this information to ensure the security of our services, and to optimize and improve our services.

Compliance information: Open ID, token, region, username

We use this information to verify your eligibility to participate in the Game.

Necessary to perform our contract with you to provide the Game

Analytics and profiling data (collected via and shared with Appsflyer, a third party SDK):

· Technical information: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier;

· Technical identifiers: IP address, user agent, identifiers for advertisers, Google Advertiser ID, Open ID; and

· Engagement information: ad clicks/impressions, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, URL from the referring website, downloads and installations, other interactions, events and actions undertaken by the user.

We use this information to carry out data analytics, app performance analytics and profiling for ad attribution purposes to understand how our users interact with advertisements.

It is in our legitimate interest to use this information to monitor the success of our advertising and marketing programs.

Analytics and profiling data (collected via and shared with Firebase, a third party SDK): user dimensions, device dimensions (age, app store, app version, country, device brand, device category, device model) and in-app events (such as number of users and sessions, items purchased and purchasing history, advertising analytics like ad clicks, ad exposure, ad impression, ad query, ad exposure, application analytics like app usage, app clearance, app crashes, app removal, app payment analytics, app update and use analytics, website usage analytics like web clicks, browser downloads, notification, video progress, search analytics), session duration, operating systems, geography, time, gender, language, first launches, app opens, app updates, in-app purchases, website usage analytics, application analytics, search analytics, Google advertising ID, ADID and IDFA, Firebase Installation ID, Open ID.

We use this information to carry out data analytics, app performance analytics and profiling for ad attribution purposes to understand how our users interact with advertisements.

It is in our legitimate interest to use this information to monitor the success of our advertising and marketing programs.

Analytics and profiling data (collected via and shared with Facebook, a third party SDK):

· Contact information: name, email address, and phone number; and

· Event data: information you share about others and the actions they take on your websites, apps, or stores, such as visits to sites, installations of apps, and purchases of products.

We use this information to carry out data analytics and profiling for app performance analytics and ad attribution purposes to understand how our users interact with advertisements.

It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.

User acquisition analytics information: Data relating to user registering (e.g. the stage at which users drop out, how long do users remain at a particular stage), logging in, game update; and browser data, PC Universally Unique ID, time zone, resolution, IP address, language, and common information for data reporting including game ID, client source, session ID, event time, client IP, country, province, city, carrier ID, Open ID, event name, OS, OS version, SDK version, network type, bundle ID, app version, log in channel ID, device model, device brand, screen width, screen height, CPU name, CPU core, CPU frequency, GPU name, RAM, ROM, system language

We use this information to analyze the user acquisition process, to better understand where all users who downloaded the Game originated from.

It is in our legitimate interest to use this information to understand the user acquisition process and to measure the effectiveness of our advertising and marketing programs.

Text chat data*:

Text chat message data (inputted by users).

*Subject to this feature’s availability in your jurisdiction and to certain users.

We facilitate the posting of your text chat communications with other users.

Necessary to perform our contract with you to facilitate communication between users where you seek to use chat services.

Real time voice chat data*:

Open ID, device name, device model, operating system, client IP, operator information, microphone signal, Wi-Fi status.

*Subject to this feature’s availability in your jurisdiction and to certain users.

We facilitate your real time voice chat with other users.

Necessary to perform our contract with you to facilitate communication between users where you seek to use chat services.

Voice message data*:

Open ID, device name, device model, operating system, client IP, operator information, microphone signal, Wi-Fi status.

Voice message data (recorded by users)

*Subject to this feature’s availability in your jurisdiction and to certain users.

We facilitate your recording of voice messages for other users to listen to.

Necessary to perform our contract with you to facilitate communication between users where you seek to use voice message services.

Security and anti-cheating-related information:

· Account information (including User ID, Game ID), device information, device identifiers (including UUID);

· location information (including IP address, country/zone); and

· gameplay data (including log data), screenshots, module loading behavior of the game process, system API calls, graphics library method calls, system procedures created (such as threads, hotkey processes, performance counter events, performance monitoring interrupts), gameplay events, replay data, information submitted by user to retrieve account (including account information, gameplay data, programs running information when playing game, device information and any information submitted by user to verify identity).

We use this information to provide a fair environment, and ensure the security and safety of the services of the Game (through anti-cheat functions like cheating countermeasure and detection based on game replay).

It is in our legitimate interest to use this information to detect and prevent cheating in the Game.

User-generated content moderation information: User account, used to identify malicious users for illegal dissemination and carry out related processing, and content generated by users such as picture URL, nickname, speech, voice, used to identify the user's content and carry out relevant processing, such as filtering or blocking accounts.

We use this information to detect if your text, pictures, voice, video and other forms of user-generated content includes content in breach of our End User Licence Agreement (such as advertising, violence, abusive text, hate, and sexual / vulgar content).

It is in our legitimate interests to ensure the integrity of the Game and protect users from prohibited conduct.

Game data (including log and in-Game behaviour data): Event Time, App ID in Google Play or Facebook, platform ID, game server ID,  Zone Area ID of user’s server location, Open ID, login channel, PP channel, system language, role ID, client IP, country, XWID, user’s behaviour in Game, and all data used to provide Taris Ranking (including profile picture, nickname, character information (including list of characters, name, level, equipment level), score (including best score), zone information, ranking (including server ranking and total ranking), battle information (including character name, date and duration), information needed to provide players with a smaller range of leaderboard data (including nickname, zone information, progress status, score, equipment level, and ranking of other players or other teams of players), damage amount, active percentage, damage per second, score, skills, percentage of using the skills, killing count, killing statistics (whether success or failure), average score of other players).

We use this information to:

· understand your game behaviour to optimize your experience in the Game;

· update your profile information and track player performance and progress;

· provide leaderboard features such as Taris Ranking; and

· provide your Twitch Drops rewards to your chosen character if you participate in the Twitch Drops Event.

It is in our legitimate interest to improve user experience of the Game.

Customer support information (in app, email, website):

· General information (received from Game): Zone name, zone ID, platform ID, role name, role icon, language type, open ID, secure position of notch screen of mobile device, scene ID, area ID, app ID, country ID, channel ID;

· Device information (automatically collected): Device ID, IP address; and

· Information collected via International SDK: Encode parameters, game ID, channel ID, OS, timestamp, SDK version, sequence no.;

· Information collected via user’s game data query: Game account information, including registered user name, social media account, mobile phone number, registration time, VIP level; Game character information, including role name, role ID, game duration, historical record; In-Game data, including information in relation to items, currency, penalties, logins, activities, top-up, purchase history, in-game friend relationships, in-Game match data; any information users provide to customer service, including chat data.

We use this information to:

· to improve our services;

· to respond to your communications; and

· to provide troubleshooting, such as addressing and remediating technical issues and bugs.

Necessary to perform our contract with you to provide and support the Game.

Survey device data: IP address, browser version, device settings and operating system version, open ID.

We use this information:

· to allow you to complete the survey (if you wish to participate) in-app; and

· to enable the Game to match the survey results with the user behaviour in game for survey results analytics purposes.

We collect this information with your consent.

Purchase information (in-app or via Steam): Open ID, country, role ID, steamID, CPU model, device model, currency, SDK version, application version, network type, IDFV, amount

We use this information:

· to enable you to use the payment function in the Game; and

· to determine your rebates and items unlocked (e.g. battle passes) if you participate in the Top-Up Rebates Event

Necessary to perform our contract with you to faciliate in-app purchases.

Purchase information (Midasbuy platform): Items purchased and price, time, date and currency of the purchase, order ID, open ID, player ID, country, game account balance and purchase history

We use this information to enable you to make purchases on the Midasbuy platform.

Necessary to perform our contract with you to faciliate purchases.

In-game events data (via Gamelet and Pandora): role ID, Open ID, platform ID, level, language, country or region

We use this information to enable you to access in-game events via Pandora.

Necessary to perform our contract with you to provide the Service.

Additional categories of data processed by the cloud version of the Game

Cloud Gaming Login: Login transmission via your relevant social media account (user ID, token for business, username, avatar)

We use this information to enable you to use the Service from a cloud server without downloading the Service in accordance with your request.

Necessary to perform our contract with you to provide the Service from a cloud server without downloading the Service.

Cloud Gaming Resource Allocation Data: IP address, and for game activities, token

We use this information to allocate cloud resources if you would like to access the Game from a cloud server without downloading the Game.   

Necessary to perform our contract with you to provide the Game from a cloud server without downloading the Game.

Cloud Gaming Performance Data: IP address, device model, device System-on-a-Chip model  

We use this information to carry out analytics on the performance and functioning of the Service on the cloud server in your city or region and of the Game’s video decoding capabilities, and to improve the functionality of the Game.   

It is in our legitimate interest to ensure the functioning of, and improve, the Game.

Cloud Gaming Network Data: WiFi strength, WiFi connection speed, whether device supports 5G, WiFi frequency, network round trip time (mobile network and WiFi), possible number of devices using same WiFi

We use this information to provide better user experience and to improve the Game

It is in our legitimate interest to improve user experience and the Game.

Cloud Gaming Duration Data: (via app) stay time on web browser session, token, token key

We use this information to determine your gaming duration (i.e., the amount of time you have spent on playing the Game from a cloud server without downloading the game), and to calculate the remaining time you have (per day) to play the game from a cloud server without downloading the Game (if applicable).

It is in our legitimate interest ensure the integrity of the Game by ensuring time limits are not circumvented.

Cloud Gaming Log Data: User ID, OpenID, IP address, device model, device System-on-a-Chip model, WiFi strength, WiFi connection speed, WiFi frequency, whether device supports 5G, possible number of devices using same WiFi, token, token key

We use this information for troubleshooting to improve the Game and user experience.   

It is in our legitimate interest to improve the Game and user experience.

In relation to the Website

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

LEVEL INFINITE PASS account log-in information email address, password, user ID, nickname, user token, open ID, country, date of birth (we do not store your date of birth on our servers)

We use this information to allow you to register, create your account for the Game Services, access the promotional activities on the Website, and receive notifications of the Game.

Necessary to perform our contract with you to provide you with updates and allow you to access  the  promotional activities, and register for the Game.

Email Address to receive updates on the Game

We use this information to send you notifications and updates about the development, progress and subsequent beta tests and launch of the Game.

We use this information only with your consent.

Email Address to register for the Game

We use this information to:

· select users to participate in subsequent beta tests and launches of the Game; and

· send users a link to download the Game via the iOS App Store or Google Play Store or a link to download the Windows version of the Game.

Necessary to perform our contract with you to register you for interest in and facilitate your download the Game.

Delivery information: Name and mailing address.

We use this information to deliver the prize to you, if you participate in the raffle feature on the Website and win a physical (not in-game) prize.

We collect this information with your consent.

Suggested Class Questionnaire information: Nickname, job category (e.g. corporate worker, manager, workman, freelancer, others), preferences for the Game and other questionnaire responses.

We use this information to allow you to complete the questionnaire (if you wish to participate) on the Website.

We collect this information with your consent.

Game-related promotional activities information (e.g. Dragon Raid Bounty and Official launch server first kill): username, email address, country of residence, information about your game zone, role, server and guild joined

We use this information to allow you to access and participate in the promotional activities.

Necessary to perform our contract with you to allow you to participate in the promotional activities.

Guild-related information: Guild name, Guild Master's nickname, Time zone, Guild Master's name, Guild Master's email address, Guild Master's discord ID.

We use this information to allow you to access and participate in Guild related activities.

Necessary to perform our contract with you to allow you to participate in the Guild related activities.

Information collected or generated as part of the Website

IP Address

We use this information to perform statistics on page view and user view on the Website.

It is in our legitimate interests to use this information to monitor the page view and user view of the Website.

In relation to Taris Ranking

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

Account log-in information: (depending on how you choose to log in):

· Facebook account login: user ID, nickname, profile picture, user token and open ID;

· Google Play account login: user ID, nickname, profile picture, user token and open ID; and

· LEVEL INFINITE PASS account log-in information: email address, password, user ID, nickname, user token, open ID.

We use this information to link your Taris Ranking account to the account you have created for the Game.

Necessary to perform our contract with you to provide Taris Ranking.

Information collected or generated as part of Taris Ranking

Character binding information:

· Open ID;

· For providing profile information: Profile picture, character information (including name, level, occupation, equipment level), score (including best score), zone information, ranking (including server ranking and total ranking), server name, average performance ranking among dungeons, total score;

· For providing score information in relation to boss battle: Name of boss, performance percentage, damage per second, battle score, ranking, equipment level;

· For providing team battle information: Battle name, date of battle, duration of battle, battle performance information of all participants in the battle in terms of amount of harm caused, amount of healing and amount of harm encountered (including nickname, contribution level, damage per second, score); and

· For providing collection information: Nickname, ranking (including server ranking and total ranking), total score.

We use this information to bind your character in the Game to provide and publish Game collection information, Game profile information, score information in relation to boss battle and team battle information on Taris Ranking to be viewed by other users.

Necessary to perform our contract with you to provide the Taris Ranking feature.

Leaderboard highlights: Nickname, damage per second, ranking within a dungeons

We use this information to ensure the integrity of the rankings and high scoring players.

It is in our legitimate interest to ensure the integrity of the rankings and high-scoring players is supported by appropriate evidence in-Game.