KRAFTON, Inc. (“we”, “company” or “us”) keep and process information about you (“you” or “user”) when you visit, access, or use our websites (“Sites”). We comply with all applicable laws related to personal information and strive to protect the rights of individual users by adopting Privacy Policy in accordance with relevant laws and regulations. This Privacy Policy(“Policy”) describes how we collect and use personal information about you during and after your relationship with us.

What personal information we collect and process depends on how and why you interact with us.

1) Collecting information directly from you

• You may provide us with the following information when using our Sites. The information you provide us may differ in some cases. For example, you may provide us with your:
  • Name, email address, residing city, industry, inquiry details, etc. to answer your inquiries related to branding or other opportunities.

2) Collecting information automatically

• We automatically collect certain information when you visit our Sites. The type of information that we automatically collect may vary, but generally includes:
  • Your device information (including OS version, model information, device ID, etc.);
  • Online identifiers (including IP address, MAC address, etc.);
  • What areas of the websites you accessed, browsed, searched for, or used; and
  • Time spent on our websites and related statistical information.

We do not use Session Data to personally identify you. We use it to administer, operate, and improve our Sites. The process by which we collect this information is through cookies-related online technologies. See our “Cookies and Related Technologies” section below for more information.

3) Information collected from third parties

• We do not collect information from third parties.

We use personal information collected through the Sites for the following purposes:

• Operating the Sites; and
• Responding to you or processing your inquiries.

We may share personal information with our service providers who help us perform and deliver our services, including:

• Cloud service provider, website management, hosting, and analytics;
• Communications;
• Form processing;
• Information technology, security, and auditing.

We may also share your information where such disclosure is essential to comply with a legal obligation or a lawful data access request.

As noted above, we use cookies and other technologies when you interact with our Sites to improve their quality, store browsing preferences, and track usage trends, among other things. For these technologies to work, third parties collect and/or receive information from our Sites and elsewhere on the internet. These third parties typically collect information in the aggregate and in a way that does not personally identify you.

Cookies are small files downloaded to your computer (if your browser is enabled to accept cookies) to track movements within websites and to customize your experience within the Site. Most Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. We do not control cookies in third party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of the Site may not function properly. To find out more about cookies, visit http://www.allaboutcookies.org/ .

We use analysis services on this site to allow us to record information on the use of this Site and to improve our offering constantly.

This Site uses Google® Analytics and related technologies, analysis services offered by Google Inc. (“Google”). We may use the following advertising functions of Google® Analytics and collect personal information as provided by Google, and you may withdraw your consent by deactivating such functions in Google’s advertising settings: Remarketing by using Google® Analytics; Google® Display Network Exposure Report; Google® Analytics Demographics and Interests Report; and Integrated service allowing the collection of data through Google® Analytics by using advertising cookies and anonymous IDs.

More information about Google’s own privacy policy can be found at https://www.google.com/policies/privacy . If you wish to opt-out from your information or data being used by Google Analytics, you may download the Google Analytics Opt-out Browser Add-on available here: https://tools.google.com/dlpage/gaoptout

We make access to our Sites available to you, globally. Consequently, to provide our Sites and/or to meet legal requirements we may transfer your data to other countries and other regions outside of where you are located. By using our Sites, if applicable, you acknowledge that your personal information may be processed in a location outside of your own. For certain countries, we process the data in certain regions (as set out in more details below).

We generally retain your personal information for the duration of your relationship with us and will delete it after the purpose of the collection is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using commercially reasonable technical measures in a way that the data cannot be reproduced.

We do not knowingly collect, use or share any personal information about children (age depending on the country where you reside) through our Sites. If you are a parent or guardian and you believe your child has provided us with personal information, you can contact us and request your child’s information to be deleted from our system.

If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave this Site and go to the website you selected. Because we cannot control the activities of third parties, we do not have responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to the Sites, you should consult that site’s privacy policy before providing any personal information.

We follow generally accepted industry standards to protect information submitted to us, both during transmission and after we receive the information. However, no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information. To make a request concerning your rights or if you have any other questions, please contact us by sending an email to the address specified in the “Contact Us” section. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Privacy Policy on our Site. We will provide notice on our Site or by other appropriate means to you if these changes are material and, where required by applicable law. You will be deemed to have accepted such amendments by continuing to use the Service, so please review it frequently.

If you have any questions about this Policy, or your dealings with this Site, please contact us by using one of the following communication channels.

• Email: privacy@krafton.com
• Address: Yeoksam Center Field 231, Teheran-ro, Gangnam-gu, Seoul, Republic of Korea

In the event of a conflict between the supplemental Terms – Jurisdiction Specific that is relevant to your jurisdiction from which you are using our sites, and the rest of the Policy, the relevant jurisdiction’s Supplemental Terms – Jurisdiction Specific will supersede and control.

If you are an EEA, Switzerland, or a UK resident, you may have additional rights.

A) International Data Transfer

• If we transfer your data outside of the EEA to a country that is not recognized by the European Commission as ensuring an adequate level of data protection, we endeavr to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the latest standard contractual clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for personal data). You may ask for a copy of such appropriate measures by contacting us as set out in this Policy. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.

B) Your Privacy Rights

• You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

C) Representative in the EU

• The GDPR(for EU Residents) requires a written designation of a representative in the EU by the controller or processor not based in the EU. Contact information and address of VeraSafe in the EU are as follows. Also to make such an inquiry about personal data processing, please contact VeraSafe using the consent form HERE.
  
  
  • Name of our Representatives: VeraSafe
  • Address: Keizersgracht 391 A, 1016 EJ Amsterdam

A) Nevada

• If you are a Nevada resident, we do not sell your personal information that we collected, Nonetheless, if you are Nevada residents who purchased our game items or goods from us, you may submit a request to record your preference to opt out for the future.

B) California

• If you are a California resident, you may have additional rights. You can check the rights in below.

This Privacy Notice (“Notice”) for California residents provided pursuant to the California Consumer Privacy Act (“CCPA”) supplements the Privacy Policy of KRAFTON, Inc. and its affiliates (“we”, or “us”) and provides additional information on how your personal information is collected, used, disclosed and processed online or offline. Unless otherwise specified, all terms used within this Notice shall carry the same meaning as they are defined in our Privacy Policy(“Policy”). This Notice and the Policy together constitute our “California Privacy Policy”.

We will collect the following categories of information that may directly or indirectly identify or describe you or your device, or information that may be reasonably capable of being associated with or reasonably linked to you or your device (“personal information”). We have collected these same categories of personal information from consumers over the past 12 months. Please refer to our Policy concerning the categories of sources from which this personal information is collected.

Also, we may provide service providers or third parties with certain personal information to provide or improve our services. Within the past 12 months, we disclosed or shared each of the following categories of personal information with the following categories of third parties. We do not ‘sold’ personal information to third parties as that term is defined by the CCPA.

1) Identifiers

• Categories: IP address, name, contact information (such as email address)
• Category of Third Parties to whom personal information was disclosed (such as cloud computing service providers)

2) Internet or other similar network activity information

• Categories: website or advertisement browsing history, device model, OS version, device storage, and information about the device that you are visiting
• Category of Third Parties to whom personal information was disclosed: cloud computing service providers

You may exercise the following rights at any point in time in connection with your personal information. To exercise such rights, please email us at privacy@krafton.com. Please note that at least your email address will be required to submit a request. If you exercise your rights via email, you must specify the right(s) you wish to exercise. We will verify your identity and respond to your request within 45 calendar days. If necessary, we can take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, provided that we notify you to explain the reason for the delay.

1) Right to Access

• You have the right to request the following information up to two times within a 12-month period. Categories of the personal information that was disclosed for a business purpose or sold during the past 12 months, and categories of third parties to whom the information was disclosed or sold.
  • The categories of personal information that we have collected from you over the past 12 months, and the specific pieces of personal information we have collected from you
  • Categories of the sources from which personal information was collected
  • Business or commercial purposes for which personal information is collected

2) Right to Request Deletion

• You have the right to request that the personal information collected from you be deleted.

3) Right to Opt-Out of Personal Information Sales

• You have the right to “opt out” by requesting that your personal information not be sold in any form. However, we do not sell personal information.

4) Right to Non-Discrimination

• You have the right to not be discriminated against for exercising your privacy rights under the CCPA.

5) Rights for California Minors

• Minors under the age of 18 have the right to request the deletion of and/or obtain information posted on websites such as forums or bulletin boards.

6) Shine the Light

• You have the right to request the categories of the personal information that we disclosed to third parties in the last year for direct marketing purposes and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for direct marketing purposes.

You may designate another person or entity (“authorized agent”) to act on your behalf in connection with your request for rights that are guaranteed by the CCPA. An authorized agent is a natural person or business entity registered with the Secretary of State to conduct business in California that you have authorized to act of your behalf to make a request to know or to delete.

In order to use an authorized agent for your request, we require that you provide signed permission to your agent. Your authorized agent can submit a request to know or delete by sending an email to privacy@krafton.com. If you contact us for the request, we will offer you an authorized form to support.

The above requirement does not apply should your agent have power of attorney pursuant to Probate Code sections 4000 to 4465. Please note that we may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Under the CCPA, your agent is responsible for implementing and maintaining reasonable security procedures and practices to protect your information and use your personal information only for the purpose of fulfilling your request.