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. Depending on your use of the Game and the jurisdiction where you are based, you may also need to provide some additional information to help us set up your account.

· 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.

· 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 including any subsequent beta tests then you will need to provide your email address and your device information.

· 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).

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 account, 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, 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 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 use the Website, optimise and improve the Website, resolve user queries, provide you with updates of the Game and the game Tarisland.

· 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 .

· 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.

Jurisdiction

Representative

Address

Contact details

EU

Proxima Beta Europe B.V.

Buitenveldertselaan 3-5

1082 VA Amsterdam

dpo_tarisland@proximabeta.com

UK

Image Frame Investment (UK) Limited

Suite 1, 3rd Floor 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB

dpo_tarisland@proximabeta.com

Region in which the user is located

Minimum age of the user

Argentina

13

Brazil

18

Canada

13

European Economic Area

16

Hong Kong

18

Indonesia

21

Malaysia

18

Philippines

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; and

· Level Infinite account log-in information (if you choose to log-in via Level Infinite account): 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 create your account for the Game 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.

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 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.

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): Open ID, country, role ID, CPU model, device model, country, 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.

In relation to the Website

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

Level Infinite 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, and receive notifications of the Game.

Necessary to perform our contract with you to provide you with updates and allow you to 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 with your consent.

Device information: whether you would like to use an iOS, Android or PC device for the Game

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

We collect this information 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.

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 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.

Player search (only top 100 players in each dungeons can be searched): Nickname, server name

We use this information to allow players search for ranked players.

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

In relation to the Twitch Drops Event

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

Account log-in information:

· Twitch account login: user ID, username; and

· Level Infinite account log-in information: open ID.

We use this information to link your Twitch account and your Level Infinite account.

Necessary to perform our contract with you to provide the Twitch Drops Event.

Information collected or generated as part of the Twitch Drops Event

Character information: List of characters

We use this information to provide your Twitch Drops rewards to your chosen character.

Necessary to perform our contract with you to provide the Twitch Drops Event.

In relation to the Top-Up Rebates Event

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

Account log-in information: Open ID, user name, channel ID, token

We use this information to access the Top-Up Rebates Event using your Game account.

Necessary to perform our contract with you to provide the Top-Up Rebates Event.

Information collected or generated as part of the Top-Up Rebates Event

Purchase information: details of past top-ups and transactions, including items (e.g. battle passes) purchased, amount.

We use this information to determine the rebates and items (e.g. battle passes) to be given

Necessary to perform our contract with you to provide the Top-Up Rebates Event.

Rebates information: rebates amount to be awarded, and items (e.g. battle passes) unlocked

We use this information to display the rebates and items to be given.

Necessary to perform our contract with you to provide the Top-Up Rebates Event.

Personal Information

Retention Policy

In relation to the Game

Account registration information

Region location (manually selected)

Email address

XWID

Information in relation to Game optimization and improvement

In-Game notifications / announcements information

Compliance information

Analytics and profiling data (AppsFlyer)

Analytics and profiling data (Firebase)

Analytics and profiling data (Facebook)

User acquisition analytics information

Game data (including log and in-Game behaviour data)

Customer support information (in app, email, website)

Survey information

Survey device data

Stored for the lifetime of your use of the Game and then deleted within 30 days thereafter or deleted manually within 30 days from our receipt of your account deletion request (whichever is earlier).

Real time voice data

Voice message data

Stored for 7 days on our servers for content moderation purposes and deleted automatically upon expiry of such period, unless any violation is found or suspected, in which case stored for the lifetime of your use of the Game and then deleted within 30 days thereafter or deleted manually within 30 days from our receipt of your account deletion request (whichever is earlier).

Text chat message data 

Stored for 7 days on our servers for content moderation purposes and deleted automatically upon expiry of such period, unless any violation is found or suspected, in which case stored for the lifetime of your use of the Game and then deleted within 30 days thereafter or deleted manually within 30 days from our receipt of your account deletion request (whichever is earlier).

Security and anti-cheating-related information

User-generated content moderation information

Stored for the lifetime of your use of the Game and then deleted within 30 days thereafter or deleted manually within 30 days from our receipt of your account deletion request (whichever is earlier).

For screenshots, replay files, content flow data (including real time voice data, voice message data and text chat message data) and other evidence, if any violation is found or suspected, the above retention period applies. However, if no violation is found or suspected, stored for 7 days after information has been collected.

Purchase information (in-app)

Stored for the lifetime of your use of the Game and then deleted within 30 days thereafter or deleted manually within 30 days from our receipt of your account deletion request (whichever is earlier).

In relation to the Website

Level Infinite account log-in information

Stored for the lifetime of your use of the Game and then deleted within 30 days thereafter or deleted manually within 30 days from our receipt of your account deletion request (whichever is earlier).

Email address to receive updates on the Game

Device informationEmail address to register for the Game

Retained for the duration you remain subscribed to receive our notifications and deleted within 7 days from receipt of your request to unsubscribe.

IP address

Stored for 2 months from collection, after which it will be deleted.

In relation to Taris Ranking