Welcome to Tarisland!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the game Tarisland (“Game”), the main website for the Game (“Website”) and webpages for displaying your score and ranking for the Game (“Taris Ranking”), for the Twitch Drops Event and for the Top-Up Rebates Event (the Game, the Website, Taris Ranking, the Twitch Drops Event and the Top-Up Rebates Event together comprise the “Game Services”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

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

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

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

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at dpo_tarisland@proximabeta.com. We have representatives for data protection purposes listed here.

1. Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Game Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. For more information about our Cookies policy, click here.

2. Children

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

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

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

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

3. How We Process Your Personal Information

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

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

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.
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 PASS account log-in information: open ID.	We use this information to link your Twitch account and your LEVEL INFINITE PASS 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.

4. How We Store and Share Your Personal Information

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

We have servers for the Game Services in Singapore, the United States, Brazil and Germany. The servers applicable to your use of the Game Services will depend upon your choice of server and/or location. We also have support, engineering and other teams who may support the Game Services, including from Singapore, Hong Kong and the People’s Republic of China.

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

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

· Third parties that provide services in support of the Game Services, including providers of services that process information identified in this policy for the purpose of providing the Game Services, third party SDKs (e.g. from Appsflyer, Firebase, Facebook) for the purpose of monitoring the success of our marketing and advertising programs and profiling, monitoring and analysing views, clicks and engagement with the advertisements displayed in the Game, which process the relevant data analytics, profiling and user acquisition data identified in the policy in servers located in the United States, Belgium and Ireland. 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., for the purpose(s) described above).

· Third party partners that we collaborate with in providing the Game Services, including app stores that distribute the Game and facilitate in-app purchases, social media platforms if you participate in our activities through the platforms or if you otherwise choose to share certain information to social media platforms linked through our Game Services (such as when you choose to open or be redirected from our Website to a social media platform to post or share content relating to the Game Services). These companies will process your personal information and govern your use of their services and products in accordance with their terms and privacy policies.

· Companies within our corporate group who process your personal information solely for the purpose of providing the Game Services to you, which may include facilitating purchases / in-Game transactions, conducting surveys and for customer support purposes. All such group companies may only use your personal information in accordance with this Privacy Policy.

· Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.

· Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

· A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

5. The Security of Your Personal Information

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

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Game 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 to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

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

Personal Information	Retention Policy
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) Purchase information (in-app or via Steam) Purchase information (Midasbuy platform) In-game events data (via Gamelet and Pandora) Cloud Gaming Login	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).
Data Subject Request Ticket Information	Stored for 3 years.
Survey information Survey device data	Stored for the lifetime of your use of the Game or one year after collection, 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.
Cloud Gaming Resource Allocation Data Cloud Gaming Performance Data Cloud Gaming Network Data Cloud Gaming Duration Data Cloud Gaming Log Data	Stored for 6 months, or termination of the Game Services, or deleted manually within 30 days from our receipt of your account deletion request (whichever is earlier).
In relation to the Website
LEVEL INFINITE PASS 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 Email 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.
Delivery information	Stored for the duration of the raffle feature and then deleted within 2 months thereafter or deleted manually within 30 days from our receipt of your deletion request.
Suggested Class Questionnaire information	Stored for the duration of the questionnaire and then deleted within 2 months thereafter or deleted manually within 30 days from our receipt of your deletion request.
Game-related promotional activity information	Stored for 60 days from the end of the activity, after which it will be deleted.
Guild-related 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).
In relation to Taris Ranking
Account log-in information	Stored for 1 month from collection on your browser, after which it will be deleted.
Character binding information	Retrieved from the Game servers with the retention periods as set out above.
Leaderboard highlights	Retrieved from the Game servers with the retention periods as set out above.
Player search	Retrieved from the Game servers with the retention periods as set out above.
IP Address	Stored for 2 months from collection, after which it will be deleted.
In relation to the Twitch Drops Event
Twitch account and LEVEL INFINITE PASS account log-in information	Stored for duration of the Twitch Drops Event and then deleted within 30 days thereafter or deleted manually within 30 days from our receipt of your account deletion request (whichever is earlier).
Character information	Retrieved from the Game servers with the retention periods as set out above.
In relation to the Top-Up Rebates Event
Account log-in information	Stored for 1 month from collection on your browser, after which it will be deleted.
Purchase information	Retrieved from the servers of purchase information with the retention periods as set out above.
Rebates information	Data is processed momentarily and is not stored on our server.

7. Your Rights

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

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

Access

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

Portability

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

Correction

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

Erasure

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

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us using the contact details at Section 8 (Contact), and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at Section 8 (Contact). Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

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

8. Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: dpo_tarisland@proximabeta.com

Mailing Address:

Tencent International Privacy & Data Protection Centre

79 Robinson Rd #07-01

Singapore 068897

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

9. Changes

If we make any 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.

INFORMATION FOR PARENTS

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

What personal information does the Game Services process?

The Game is a mobile game.

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

· Log-in information: Open ID, and other information if relevant, such as email address.

· Customary device and network information: such as IP address, connection speed, device specifications, as well as app- and OS-generated identifiers.

· Customer support information: such as details of ticket, complaint and handling, name, open ID, device and network information.

· Game data, crash and analytics information.

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

Does the Game Services process personal information differently for children?

Children will not be able to access free chat function and can only communicate using the quick chat function by selecting pre-set text messages. Children will also not be able to use real-time voice chat and voice messages recording function.

Why is my consent required?

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

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

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

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

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

Will you retain my personal information?

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

What if I do not consent?

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

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

You can withdraw your consent or delete your child’s account by emailing us at dpo_tarisland@proximabeta.com. You can also request a copy of your child’s personal information at any time.

Our Representatives in Certain Jurisdictions

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	4th Floor 80 Strand, London, United Kingdom WC2R 0RL	dpo_tarisland@proximabeta.com
Serbia	Karanovic & Partners o.a.d. Beograd	Resavska 23, Belgrade, 11000, Serbia	local.representative@karanovicpartners.com
Thailand	Tencent (Thailand) Company Limited	8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand	dpo_tarisland@proximabeta.com
Türkiye	Özdağıstanli Ekici Avukatlık Ortaklığı.	Nidakule Ataşehir Kuzey Begonya Sok. No:3 Kat. 17 D: 162 34746 Ataşehir / İstanbul, Türkiye Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-Game conduct, suspensions, investigations, civil or criminal complaints.	turkeydatarep_proximabeta@iptech-legal.com

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

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

Algeria

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

Argentina

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

Australia

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

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

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

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

Bangladesh

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

Brazil

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

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

Canada

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

Colombia

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

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

France

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

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

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

Indonesia

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

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

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.

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

Kazakhstan

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.

By accepting the Privacy Policy, you consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information as described in this Privacy Policy. The transfer of your personal information to third parties, which may include the cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, to Singapore.

In the event of any discrepancy or inconsistency between the English version and the Kazakh version of this Privacy Policy, the Kazakh version shall prevail.

Your Rights

· Right of access: You have the right to request access to and obtain a copy of the personal information we have processed about you or that is being processed on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

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

· Right to blocking / de-blocking: You have the right to request the blocking of personal information related to you, if you become aware of a violation regarding the collection and processing of your data. If the violation has not been proved, you may request to de-block your data.

· Right to deletion: You have the right to request deletion of your personal data if the collection and processing of your data has been conducted in violation of Kazakh laws.

· Processing of your personal information in public sources of personal data: You may request to limit or provide your consent to the processing of your personal information in public sources of personal data.

Malaysia

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

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

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

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

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

· Our data protection officer, responsible for the management and safety of your personal information

o Telephone: +603-22872388

o Email: dpo_tarisland@proximabeta.com

Mexico

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

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

To understand more about and exercise your rights to “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes limitation to the use and disclosure of your personal data, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us.

New Zealand

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

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

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

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

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

Peru

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

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

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

· Data Protection Team, responsible for the management and safety of your personal information

· Contact: as set out in Section 8 (Contact)

Philippines

You are entitled to the following rights:

· Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.

· Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for automated processing or profiling.

· Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.

· Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.

· Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

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

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

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

· transferring or storing your personal information in destinations outside the Philippines as described in Section 3 (How We Store and Share Your Personal Information)

Serbia

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

· Name: Karanovic & Partners o.a.d. Beograd

· Address: Resavska 23, Belgrade, 11000, Serbia

· Telephone Number: +381 11 3094 200

· E-mail: local.representative@karanovicpartners.com

Singapore

By accepting this Privacy Policy, you consent to the collection, use and disclosure of personal data as set out in this Privacy Policy, including cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, the locations specified in Section 4 (How We Store and Share Your Personal Information). In situations where consent is not obtained, Proxima Beta collects, uses, or discloses personal data in accordance with an exception under the Personal Data Protection Act 2012 or as required or authorized by any other applicable law.

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

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted here.

South Africa

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

Sri Lanka

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

Thailand

By accepting this Privacy Policy, you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the Game Services.

If you are under the age of 20, you undertake that you have obtained your parent or legal guardian’s consent to register an account on and use the Game Services.

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

· withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;

· request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;

· request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or

· lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us.

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in Section 8 (Contact) and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

Türkiye

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

· learn whether or not your personal data has been processed;

· request information about processing if your personal data has been processed;

· learn the purpose of processing of your personal data and whether they have been used accordingly;

· know the third parties in the country or abroad to whom personal data has been transferred;

· request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

· request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

· object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and

· demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

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

Identity of the overseas recipient	Location of the recipient (or as otherwise stated in the recipient’s privacy policy)	Purposes of use of Personal Information by the recipient	Items of Personal Information to be provided
Tencent Cloud (cloudlegalnotices@tencent.com)	Singapore	Storage of personal information	All personal information collected
Midas	Singapore	Payment	Payment information
IMUR	Singapore	Survey	Survey Information

United States

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”).

Collection and Disclosure of Personal Information

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

· Identifiers, such as your name as it appears on your social media profile, your LEVEL INFINITE PASS account username, Open ID / user ID, IP address, device ID, device token, phone number, email address, and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.

· Characteristics of protected classifications under California or federal law such as national origin, gender, or age. This information is collected directly from you in the context of being our consumer or, if you choose to set up your profile using a social media account, your gender may be provided by your social media account provider.

· Personal information categories listed in the California Customer Records statute, including information covered by other categories such as you address and phone number. This information is collected directly from you.

· Internet or other electronic network activity information, such as your information regarding your use of the Game Services, including level, score, 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.

· Commercial information about any transactions within the Game such as what products were purchased and how much they cost. This information is collected directly from you and your device and the Google Play or Apple iOS store.

· Geolocation data such as your region location when you set up your profile and choose to provide this information for the Game Services. This information is collected directly from you.

· Audio and visual information such as your social media profile picture and audio messages. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.

· 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.

· Account log-in information, including the username and password used to access your Game Services account.

· Contents of your chat messages sent in the Game. Unless otherwise stated in this Privacy Policy, this information is collected from your device, is only stored on your device, and is not retained by our servers.

We collect and disclose your personal information for the following purposes:

· To provide you with the Game Services, maintain your account, provide customer service, process payments, and deliver audio and text messages.

· To process surveys.

· To improve our services, including the functionality of the Game Services.

· 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 Section 3 (How We Process Your Personal Information).

We disclose each of the categories of personal information that we collect to the following types of entities as described in Section 4 (How We Store and Share Your Personal Information).

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “Share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.

Retention of Your Personal Information

The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.

California Users Under 18

Any California residents under the age of eighteen (18) who have registered to use the Game Services and who have posted content or information on the Game Services can request that such information be removed from the Game Services by contacting us as specified in Section 8 (Contact). Such request must state that they personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the resident cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post, and archived copies of it may be stored by search engines and other parties that we do not control.

Rights under US State Laws

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law:

· Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:

o the categories of personal information about you that we collected;

o the categories of sources from which the personal information was collected;

o the business or commercial purposes for collecting personal information about you;

o 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

o the specific pieces of personal information we collected about you;

· Request to Delete. Request we delete personal information we collected from you;

· Request to Correct. Request we correct inaccurate personal information that we maintain about you; and

· Right to Non-Discrimination. 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 US State Laws.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 8 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.

Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

Questions

If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 8 (Contact).

*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.