Assassin’s Creed Codename Jade
Privacy Policy
Last Updated: August 3, 2023
Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.
Please note that this privacy policy (“Privacy Policy”) only applies to the game Assassin’s Creed Codename Jade (the “Service”). If you use any other products or services, please refer to the privacy policy for that particular product or service.
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.
For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited.
SUMMARY
Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.
What information do we need to be able to provide the Service? | · If you register an account to use the Service then we will need some information from you to set this up, such as your account nickname. We will collect your UID, token, email, password to link your game account to your LEVEL INFINITE PASS account. We will generate an Open ID, which is an internal ID for your account. Depending on your use of the Service and the jurisdiction where you are based, you may also need to provide some additional information to help us set up your account. · To maintain the smooth operation of the Service (which includes activities from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information (such as IP address, connection speed, device specifications, as well as app- and OS-generated identifiers). · If you choose, you can provide other information to personalise your experience of the Service or enable game features. This includes chat features. · If you need to get in touch with us, we will review information you provide to respond to your concerns. | |
How will we use your information? | · We use your information to set up your account, enable you to use the Service, localise the Service experience, enable interaction between users, save your progress, ensure the safe and secure operation of the Service, address bugs, conduct surveys, send notifications of game events and updates, optimise and improve the Service, protect users, resolve user queries, to monitor our marketing activities, and to comply with our legal obligations and enforce our legal rights. | |
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 storage, for surveys, to monitor our marketing activities, and to send notifications of game events and updates). · 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 Service (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. | |
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 Service in Singapore, Germany (for EEA, UK and Türkiye users) and the United States (for US and Canada users). The servers applicable to your use of the Service will depend upon your location. We also have support, engineering and other teams who may support the Service, including from Singapore. Certain personal information processed for marketing and notification purposes may also be stored and processed by our third party partners, including AppsFlyer and Google Firebase, on their servers in accordance with their privacy policies. · 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. | |
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 Service, 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. | |
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. | |
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. |
Welcome to Assassin’s Creed Codename Jade!
This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the game Assassin’s Creed Codename Jade (the “Service”), 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 Service. 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 Service. By using the Service 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 Service is Proxima Beta Pte. Limited (“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_acm@proximabeta.com. We have representatives for data protection purposes listed here.
Children must not use the Service for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction).
By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions we have listed the relevant minimum age 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.
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.
Region in which the user is located | Minimum age of the user |
Canada | 13 |
European Economic Area | 16 |
Türkiye | 18 |
United Kingdom | 13 |
United States | 13 |
This section provides more detail on the types of personal information we collect from you, and why.
For users who live in the European Economic Area, Türkiye or the United Kingdom, it also identifies the legal basis under which we process your data.
Personal Information | Use | Legal Basis (where applicable) |
Information you provide to us (either directly or through a third party) | ||
Account Creation Information: Nickname, Open ID | We use this information to create your account for the Service in accordance with your request. | Necessary to perform our contract with you to provide the Service. |
LEVEL INFINITE PASS Account Information (provided by LEVEL INFINITE PASS to enable you to log in via your LEVEL INFINITE PASS account): UID, token, email, password, country/region, age status (whether you are a child or not) | We use this information to link your game account to your LEVEL INFINITE PASS account in accordance with your request. | Necessary to perform our contract with you to provide the Service. |
Account Deletion Verification Information: Email address | We use this information to send you verification and confirmation emails if you choose to request account deletion. | Necessary to perform our contract with you to delete your account upon your request. |
Information generated as part of the Service | ||
XWID: Your XWID, which is generated by us | We use this information to perform general/overall game analytics (for debugging), and to enable you to use the Service as a guest user. | It is in our legitimate interest to conduct app analytics and to enable you to use the Service as a guest if you wish to. |
Common data reporting information: 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, login channel ID, device model, device brand, screen width, screen height, CPU name, CPU core, CPU frequency, GPU name, total RAM, total ROM, system language, UAID | We use this information for data analytics purposes. | It is in our legitimate interest to use this information for game analytics purposes to monitor the operation of the Service. |
Data monitoring information: error code, error message, SDK name, SDK version, request URL, response body, sequence ID, stage, log, common data reporting information | We use this information to fix bugs, and to understand the performance and interaction of our SDKs. | It is in our legitimate interest to use this information to fix bugs and monitor the performance of our SDKs. |
In-Game Notification Information: Open ID | We use this information to send you in-game notifications and announcements. | Necessary to perform our contract with you to provide the Service. |
Game Server Navigation Data: Open ID | We use this information to allow you to connect to our server. | Necessary to perform our contract with you to provide the Service. |
Compliance Information: Open ID, token, country/region, age status (whether you are a child or not), username and email address | We use this information to verify your eligibility to use the Service. | Necessary to perform our contract with you to provide and support the Service. |
Location Suggestion Information: IP address Please note that this data is not stored by us. | We use this information to allow you to use the Service and to support the registration process. | Necessary to perform our contract with you to provide and support the Service. |
Game Analytics Information: · User region (country, province, city, carrier ID, region, IP address) · Device information (application version, application ID, battery information, WiFi strength, available space, network type, OS version, OS name, carrier, country code, device language, device resolution, brand, manufacturer, device model, RAM, ROM, CPU and GPU information, game frame information, mobile signal strength, network round trip time, network bytes received/sent, login step event information, XWID, network delay, packet loss rate, count of android apps) | We use this information: · for general game analytics to review and improve game performance; and · to provide troubleshooting, such as addressing and remediating technical issues and bugs. | It is in our legitimate interests to conduct game analytics to improve the game, and to provide and support the Service. |
Advertising Information (collected via and shared with Appsflyer, a third party service): · Technical information: technical information related to your device, such as 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: unique identifiers that generally only identify your device, browser or application, for example, IP address (which may also provide general location information), user agent, IDFA and Open ID. · Engagement information: your interactions with our advertisement campaigns, such as: downloads and installations of the Service and other interactions, events and actions we measure and analyse within our Service (add to cart, in-app purchases made, clicks, engagement time, etc.). | We use this information for ad attribution and to monitor the success of our marketing campaigns. | It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs. |
Crash-related information: device information (device name, device model, phone memory, CPU usage rate, CPU model, device system version, device brand (Android), ROM, RAM, CPU architecture, root status, remaining external SD card space (Android), remaining memory, whether simulator is used, running process information, system time, XWID / IDFV), process name, network type, application information (version and package name), SDK version, SDK version number / application name and version number | We use this information to collect crash-related information when crashes occur to locate and solve crashes. | It is in our legitimate interest to use this information to ensure the security and integrity of the Service and to improve our services. |
Account Deletion information (H5): email address, region, Open ID, user token | We use this information to allow you to delete your account upon your request. | Necessary to perform our contract with you to delete your account upon your request. |
System Notification Information: Firebase installation ID | This information is used to provide you with notifications on your device about the Service. This information is processed by Google Firebase only. | Necessary to perform our contract with you to send you notifications about the Service. |
Security-related Data: · For Android: system version, brand, CPU architecture, system boot time, country code and language, root status, whether simulator is used, running process information, module information of process, file name list under SD card application cache directory, application package name, process name, application version, startup time, target feature file of SD card, host file, screen recording status, plug-in real-time detection, uploading of suspicious APK files, critical system library files, Open ID · For iOS: system version, brand, CPU architecture, language region, IDFV, jailbreak status, external file detection status, application package name, application version, startup time, process name, screen recording status, uploading of suspicious dylib files information, plug-in real-time detection, VPN connection status, Open ID | We use this information for anti-cheating purposes, including to detect and observe cheating behaviours and monitor the presence and operation of suspected cheating activity and domain name hijacking. | It is in our legitimate interest to ensure the security of our Service and to maintain a fair gaming environment. |
Profanity Filtering Information: server information, text chat data and log data of SDK (including packet records of SDK, IP information of server) | We use this information to filter profanity, abusive language or other similarly objectionable uses of chat and to take action against users who engage in objectionable uses of chat. | It is in our legitimate interest to ensure the integrity of the Service and protect users from prohibited conduct. |
Survey Response Information (via IMUR): survey responses (including your gender, age range, country or region of residency, income information, education data, nickname, Open ID, game preferences) and any other content you choose to provide as part of a survey response | We use this information to enable you to complete our surveys (if you wish to do so), to better understand our users and to improve the Service. | We collect this information with your consent. |
Survey Device Information (collected directly by IMUR): browser information and user agent information (IP address (to suggest location), browser version, device settings, operating system version) | This information is used to optimize and provide surveys. | It is in our legitimate interest to optimise your user experience. |
Survey User Information (collected directly by IMUR): user ID, Open ID | This information is used to enable you to complete our surveys (if you wish to do so). | Necessary to perform our contract with you to provide and support the Service. |
Gameplay Status Data: · Player ID, Open ID · Gameplay statistics and status: game play statistics, e.g. player level, in-game performance, scores and date and time stamps of actions, purchased items, virtual currency · Player’s chosen location · Device information: Phone memory, device brand, device system version, device manufacturer, ROM, screen resolution, RAM, system time, device model, device ID, device name, CPU model, CPU architecture, XWID | We use this information to: · to improve the Service and its functionality; · maintain a record of log-in and actions of your account; · for security and verification purposes; · for general/overall game analytics (not confined to error-fixing or debugging); and · to provide you with feedback and information about your gameplay and progress. | All data (excluding XWID): Necessary to perform our contract with you to provide the Service. XWID: It is in our legitimate interests to conduct app analytics and to ensure the smooth operation of the Service. |
Version Updates Data (GCloud SDK): Open ID, device name, device model, login channel ID | We use this information to detect and download game updates. | Necessary to perform our contract with you to provide the Service and allow you to play the latest version of the game. |
Configuration Download Data (Gcloud SDK): Open ID, device name, device model, login channel ID | We use this information to manage integrated SDKs and for configuration distribution. | Necessary to perform our contract with you to provide the Service. |
Server Navigation Data (Gcloud SDK): Open ID, device name, device model, login channel ID | We use this information to allocate game servers. | Necessary to perform our contract with you to provide the Service. |
Voice Chat Data: Open ID, device information (device name, device model, client exports IP, UUID, system time), SDK version IP address, network type, voice file | We process this information to allow you to send voice messages to other users and to convert voice messages into text messages. We may also review this information to investigate reports by users of, and protect users from, prohibited conduct such as abusive language. | Necessary to perform our contract with you to provide the Service and enable communication between users. It is also in our legitimate interest to ensure the safety, integrity and fairness of the Service and to allow users to enjoy the voice chat function. |
Text Chat Data (lobby chat and private message chat): Open ID, role ID, username, text chat, chat log | We facilitate the posting of your communications with other users. We also maintain a chat log and may review text chat content to investigate reports by users of, and protect users from, prohibited conduct such as abusive language. | Necessary to perform our contract with you to provide the Service and enable communication between users. It is also in our legitimate interest to ensure the safety, integrity and fairness of the Service and to allow users to enjoy the text chat function. |
Game Log Data: Open ID, IP address, XWID, other game log information (role ID, network connection, user nickname, country code, device information (device system version, device brand, device model, device manufacturer, device name, screen resolution, screen orientation, CPU model, GPU information, RAM, client exports IP, phone memory, login channel ID, operator name, network type, signal strength, and game data (such as player level, equipment, task, achievement) | We use this information to enable you to use the Service, including: · to connect you to the server; · to maintain a record of log-in and actions of your account; · to improve the Service, including the functionality of the game; · for security and verification purposes; and · to provide feedback and information about gameplay and progress. | All data (excluding XWID): Necessary to perform our contract with you to provide the Service. XWID: It is in our legitimate interests to conduct app analytics and to ensure the smooth operation of the Service. |
Customer Support Information: any information you provide to seek customer support via Discord | We use this information to provide support, troubleshooting and to improve our services. We do not collect or store this information. | Necessary to perform our contract with you to support the Service. |
We have servers for the Service in Singapore, Germany (for EEA, UK and Türkiye users) and the United States (for US and Canada users). The servers applicable to your use of the Service will depend upon your location. We also have support, engineering and other teams who may support the Service, including from Singapore.
Advertising Information that is collected via and shared with AppsFlyer, a third party service, may also be stored and processed on AppsFlyer’s servers in Belgium and Ireland in accordance with its privacy policy. System notification information may also be stored and processed by Google Firebase at any of its or its agents’ facilities in accordance with its privacy policy.
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 Service, including providers of services that process information identified in this policy for the purpose of providing the Service, such as cloud services (Tencent Cloud) that process information identified in this policy on their servers in Singapore, Germany (for EEA, UK and Türkiye users) and the United States (for US and Canada users), ad attribution services (AppsFlyer) that monitor the success of our marketing and advertising programs and cloud messaging services (Google Firebase) that deliver system notifications. 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 Service (i.e., for the purpose(s) described above).
· Companies within our corporate group who process your personal information solely for the purpose of providing the Service to you. 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.
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 Service or otherwise via the Internet; any transmission is at your own risk.
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.
Personal Information | Retention Policy |
Account Creation Information LEVEL INFINITE PASS Account Information In-Game Notification Information Game Server Navigation Data Compliance Information Account Deletion Verification Information Game Analytics Information Advertising Information Crash-related Information Security-related Data Survey Response Information Survey Device Information Survey User Information Gameplay Status Data Version Updates Data (GCloud SDK) Configuration Download Data (GCloud SDK) Server Navigation Data (GCloud SDK) Text Chat Data Game Log Data Common Data Reporting Information Data Monitoring Information | Stored for the duration of the Service and removed within 30 days thereafter (unless you request for account deletion, in which case such data is deleted within 30 days). |
Voice Chat Data | Saved for 8 days and removed within 30 days thereafter (unless you request for account deletion, in which case such data is deleted within 30 days). |
System Notification Information | Firebase installation ID is deleted by Google Firebase within 180 days of a deletion request. |
Location Suggestion Information | Not stored by us. |
Profanity Filtering Information | Data other than text chat data: Stored for the duration of the Service and removed within 30 days thereafter (unless you request for account deletion, in which case such data is deleted within 30 days). Text chat data: Only processed momentarily to filter profanity, abusive language or other similarly objectionable uses of chat and to take action against users who engage in objectionable uses of chat. Objectionable content will be stored for the duration of the Service and removed within 30 days thereafter unless user requests for account deletion, in which case deletion will be made within 30 days upon such request. |
Account Deletion Information | Data will be retained for 30 days during the cool down period. |
Customer Support Information | We do not collect or store this information. |
Some jurisdictions’ laws grant specific rights to users of the Service. 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 you have made available as part of your account by logging into your account.
Erasure
You may be able to delete your account, or remove certain personal information, by logging into your Service account. 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 Service 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 at dpo_acm@proximabeta.com or using the contact details set out below, 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 dpo_acm@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. 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 Service 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.
Please get in touch with us if you have any questions. You can reach us in the first instance at:
Email: dpo_acm@proximabeta.com
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.
If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.
Jurisdiction | Representative | Address | Contact details |
EU | Proxima Beta Europe B.V. | Buitenveldertselaan 3-5 1082 VA Amsterdam | |
UK | Image Frame Investment (UK) Limited | Suite 1, 3rd Floor 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB | |
Türkiye | Özdağıstanli Ekici Avukatlık Ortaklığı. | Varyap Meridian Grand Tower ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul 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-Service conduct, bans, investigations, civil or criminal complaints. | turkeydatarep_proximabeta@iptech-legal.com |
SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS
Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.
California
This section applies to California residents covered by the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”). For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the CCPA and do not include information excluded from the CCPA’s scope.
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 Open ID, user ID, user token, IP address, device ID, device token, role ID, email address, nickname, XWID, UUID, UAID, and related advertising ID as described in the main Privacy Policy. This information is collected directly from you and your device and from LEVEL INFINITE PASS when you link your game account to your LEVEL INFINITE PASS account.
· Internet or other electronic network activity information, such as your information regarding your use of the Service, including level, score, date and time stamps of actions, log-in and data monitoring information, common data reporting information and engagement information as described in the main Privacy Policy. This information is collected directly from you and your device.
· Device information, such as application version, application ID, battery information, WiFi status and strength, memory, available space, OS version, OS name, device language, device resolution, brand, manufacturer, device model, and other device information as described in the main Privacy Policy. This information is collected directly from you and your device.
· Game-related data, such as player level, equipment, task, achievement and other gameplay status data and game log data as described in the main Privacy Policy. This information is collected automatically when you use the Service.
· Communication data, such as your chat data if you enable chat service. This information is collected directly from you.
· Geolocation data such as your region location provided when you set up your profile or as part of your survey responses, or collected to support the Service. This information is collected directly from you and your device.
· Audio information such as your audio messages. This information is collected directly from you.
· Education data if you choose to provide it in a survey. This information is collected directly from you.
· Other information described in subdivision (e) of Section 1798.80, including information about your gender or age. This information is collected directly from you in the context of being our consumer.
We collect and disclose your personal information for the following purposes:
· To verify eligibility for use of the Service.
· To provide you with the Service, maintain your account and deliver audio and text messages.
· To provide you with feedback and information about your gameplay and progress.
· To process surveys.
· To improve our services, including the functionality of the Service.
· For security and verification purposes, including to prevent and detect fraudulent activity.
· To address and remediate technical issues and bugs.
· To provide you with notifications about the Service.
· To monitor the success of our advertising and marketing programs.
· To ensure the integrity of the Service, to protect users from prohibited conduct and to maintain a fair gaming environment.
For additional information about what each type of personal information is used for, see Section 2 (How We Process Your Personal Information).
We disclose each of the categories of personal information to the following types of entities:
· Other companies within our corporate group who process your personal information in order to operate the Service.
· Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
· Regulators, judicial authorities and law enforcement agencies and other third parties where reasonably necessary to comply with a legal obligation; enforce our terms and conditions; detect and prevent fraud or security issues; and to protect ours and others’ rights, property or safety.
· Entities that acquire all or substantially all of our business.
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. In the past 12 months, we may have collected the following types of sensitive personal information about you:
· Your chat data
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 Section 5 (Data Retention).
Rights under the CCPA:
If you are a California resident and the CCPA does not recognize an exception that applies to you or your personal information, you have the right to:
· Request we disclose to you free of charge the following information covering the 12 months preceding your request:
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 purpose 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 we delete personal information we collected from you, unless CCPA recognises an exception;
· Request we correct inaccurate personal information that we maintain about you; and
· Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.
We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
How to Exercise Your Rights
First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 7 (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 you to provide certain information such as your country/region, user email address, screenshot of user ID and user nickname, account registration date, login method, username of linked LEVEL INFINITE PASS account, account balance, or any other information necessary to verify your identity.
Under the CCPA, 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.
Questions
If you have questions or concerns regarding this Privacy Policy, please contact us as specified in Section 7 (Contact).
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 7 (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.
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, your heirs, or, unless otherwise provided for, in the event of the death of the designated person, their 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 7 (Contact).
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 | Singapore | Storage | All personal data collected |
Germany | All personal data collected, except for personal data collected for login via your LEVEL INFINITE PASS account | ||
AppsFlyer | Belgium and Ireland | To monitor the success of our advertising and marketing programs | Advertising information |
Google Firebase | Anywhere Google or its agents maintain facilities, as described on Google Firebase’s privacy and security page | To provide notifications about the Service | System notification information |
Virginia
This section applies to Virginia residents covered by the Virginia Consumer Data Protection Act (“VCDPA”). For purposes of this section, “personal data” and “sensitive personal data” have the meanings given in the VCDPA and do not include information excluded from the VCDPA’s scope.
If you are a Virginia resident and the law does not recognize an exception that applies to you or your personal data, you have the right to:
· request that we disclose to you the personal data that we collect, use, or disclose, and information about our data practices.
· request we delete personal data we collected from you, unless the law recognises an exception;
· request we correct inaccurate personal data that we maintain about you;
· 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 law.
We do not collect sensitive personal data about you. We also do not process personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
How to Exercise Your Rights
First, you may wish to log into your account and manage your data from there. If you are a Virginia resident to whom the VCDPA applies, you may also exercise your rights, if any, regarding other data by contacting us as set out in Section 7 (Contact).
How to Appeal Decision on Your Request
If you would like to appeal a decision on your request to exercise any right you have under the VCDPA, you may contact us as set out in Section 7 (Contact).