GRAVITY CO LTD.
PRIVACY POLICY
(Effective Date: June 29, 2023)
Gravity Co., Ltd. (“Company,” “we”, “us” or “our”) maintains this Privacy Policy (“Privacy Policy”) that summarizes our policies and processes on how we collect, use disclose, transfer and store your personal information. The Privacy Policy applies only to the collection, use and storage of personal information that you may decide to provide to us in your use of: (1) our website(s) (our “Sites”), (2) our applications for mobile platforms or devices and our web applications accessible on social networking services (“SNS”) (collectively, our mobile and web applications are referred to herein as, the “Applications”), (3) our game publisher networks, crowd sourcing service and platforms (collectively, “Networks”) provided in connection with Applications and third-party applications utilizing our Services (“Third Party Mobile Applications”) and (4) chat rooms, blogs, web forums, messaging boards or other public forums in Applications and our Sites (collectively, our “Forums”). The Applications, Networks, Sites and Forums are referred to herein collectively, as the “Services”.
By accepting our Privacy Policy and the applicable Terms of Service during Service account registration or by otherwise accessing or using our Service(s) you are agreeing to the terms and conditions of this Privacy Policy (including our collection, storage, use and disclosure of your personal information) and that your access or use of the Service(s) is also subject to the applicable Terms of Service.
1. Collecting Personal Information
Our primary goal in collecting the information described below is to provide you, the user, with a customized experience on our Service and to deliver better service, products, and more relevant content to our customers, prospective customers, and visitors.
1) Personal Information We Collect
Personal information may be collected from you during your use of the Service, including, during (a) the registration process, (b) promotional campaigns, (c) customer support and technical service requests, and/or (d) ordering and use of products and other services, or from and through third party service providers and partners.
Information Collected Directly From You
Registration Information. When you communicate directly with us, either through an Application, at our Site, a Network or Forum, you are authorizing us to collect, store and use/share information collected from you in accordance with this Privacy Policy. Such information may include: (i) your age or birthday; (ii) your first and last name; (iii) your valid e-mail address and telephone number; (iv) password and other information necessary to ensure security of your account; and (v) such other information you choose to provide to us such as billing information, profile photo, photo representation (avatar), character name, interests and hobbies, game play preferences, and links to profiles on various SNS.
From time to time we may expand or change the information requested upon registration or log-in, so this may not be a complete list. We ask that you provide only your own personal information, not personal information concerning anyone else.
Usage Information. We collect details of your use of our Services and the resources that you access. Such usage information include information about how and when you access or use our Services (such as Games accessed, game score, pages visited, purchase and use of Virtual Money and/or Virtual Goods, the details of your purchases, and your game play).
Interaction and Communications among Users. We collect information about (i) your interaction with other users (for example, invite, gift, sharing of your rank or level, screen-shots, etc.) and (ii) your communication and interaction with your contacts through social media channels (including, social network services, messengers, and any other services which has social features like invite friends and sharing information with friends).
Information Through Mobile Devices. When you use an Application or Third Party Mobile Application on your mobile telephone or other mobile devices (“Mobile Device”), in addition to such information described above, you are authorizing us to collect, store and use/share the following information (as applicable): (i) Mobile Device type; (ii) mobile carrier; (iii) Internet Protocol address; (iv) geographic location/country; (v) platform version; (vi) navigation, interaction and engagement information regarding our users (vii) MAC address, International Mobile Equipment Identity (IMEI), display resolution, time and date on screen of Mobile Devices and; (viii) such other information you choose to provide to us. In addition, we receive and store information you provide when you sign up to have Short Message Service (“SMS”) notifications set directly to your Mobile Device.
Payment and Billing Information. If you purchase any in-Service items, our third party partners will collect the payment and billing information necessary to complete the transaction. Such information may include: (i) your first and last name; (ii) your valid e-mail address; (iii) credit card, PayPal and other third party payment processor information; (iv) billing address; and (v) such other information you choose to provide. Our third party partner may also receive the foregoing information that you provide when you purchase Applications and Third Party Mobile Applications through your Mobile Device.
Customer Service and Support. When you send email or other communications to us in connection with customer service and support, we will collect and store your contact information, information about your use of the Service, your user ID and such other information you provide to us in order to process your inquiries, respond to your requests and improve our Service. We will also store the correspondence and any information contained therein.
Profile Information. We provide areas on our Service where you can post information about yourself and others and communicate with others or upload content such as photographs. Such postings are governed by the applicable Terms of Service. In addition, such postings may appear on other websites or services, or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable areas, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.
Information Received from SNS and APIs
When you use an Application at an SNS, you allow us to access certain information from your profile through such SNS and the applicable SNS platform Application Programming Interface (“API”). The information we receive varies by the Application and by the privacy settings you choose for the SNS and may include any or all of the following information, as allowed by you, the SNS and your privacy preferences: (i) your first and last name; (ii) your profile picture or its URL; (iii) your user ID number; which is linked to publicly available information such as name and profile photo; (iv) the user ID numbers for your friends that are also connected to our Application(s); (v) login e-mail you provided to the SNS when you registered; (vi) your physical location and that of your access device(s) and (vii) your gender.
By using our Application(s) through an SNS, you are authorizing us to collect, store and use/share any and all information you agreed the SNS could disclose to us through the API in accordance with this Privacy Policy. Your agreement is evidenced when you “accept” or “allow” (or comparable terms) one of our Applications on an SNS.
2) How We Collect Personal Information
Automated Information Collection Technologies
As described below, when you access our Services, we collect certain technical information and may associate such information with your user or account ID number for our internal use.
Cookies
A “cookie” is a small text file that is sent to your browser from a web server and stored on your computer’s hard drive. We may use cookies to track general, non-personal information about our users (e.g., user name, pages viewed, time spent on our Site(s), games, and the sites visited just before and just after our Site(s)) for statistical and market research purposes.
We use cookies to gather information about our users’ browser activities in order to constantly improve our Service. This information assists us to design and arrange our web pages in a most user-friendly manner and to continually improve our Service to better meet the needs of our customers, prospective customers, and visitors.
We may also use local shared objects known as “flash cookies”, which help us to prevent fraud, remember your in-game settings and to track your progress on certain in-game tasks.
You have choices with respect to cookies. By modifying your browser preferences, you have the option to reject all cookies, or limit the type of cookies you allow. Flash cookies operate differently from browser cookies and cookie management tools available in a web browser will not remove flash cookies. To learn more about and manage flash cookies you can visit www.adobe.com Rejecting or limiting the type of cookies may, however, in limited instances prevent you from accessing certain features on our Service.
Log Files
Like most Internet services, we may also use log files on the server side. The data held in log files includes your computer’s or Mobile Device’s IP (Internet Protocol) address, browser type, browser language, e-mail application, Internet service provider, referring/exit Web pages, computer platform type, date/time stamp, and user activity. Company uses server log data to analyze trends, administer the services offered through our Service. We and our third party partners may use this information for product and service improvements, and in marketing and advertising services.
The software enabling our Services has associated log and temporary files that are stored on Company’s servers. These files store your account information, preference settings, system notifications as well as other data necessary to enable you to participate on our Service. Your information may also exist within regularly performed server backups.
Tracking Technologies
Our Services may utilize a variety of methods for tracking purposes, including web beacons (also known as Internet tags, pixel tags and clear GIFs). Web beacons are small pieces of data that are embedded in images on the pages of websites to analyze the traffic patterns, such as the frequency users visit various areas of our Services. Pixel tags may allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation. These methods may involve transmitting information either directly to us or to another entity authorized by us to collect information on our behalf. We also use these technical methods in HTML e-mails that we send our guests to determine whether our guests have opened those e-mails or clicked on links in those e-mails. With web beacon technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address.
Third Party Advertisers
Many advertisements are managed and placed on the service by third parties. These third party advertisers may use cookies, web beacons or similar automated information collection technologies on your computer or Mobile Devices to help present, better target, and measure the effectiveness of their advertisements, by collecting non-personally identifiable information when you click on or move your cursor over one of their advertisements. We may share certain non-personally identifiable information about you as a user with certain third party advertisers to help them deliver more relevant advertisements through their ad networks. In some cases, we may have access to information from cookies, web beacons and similar automated information collection technologies used by third party advertisers on our Services and this information may permit us to identify other sites or services that you have visited that are also associated with the third party advertiser.
The use of cookies, web beacons, or similar automated information collection technologies by third party advertisers is subject to their own privacy policies. Finally, once you have clicked on an advertisement and have left the Service, our Privacy Policy no longer applies and you must read the privacy policy of the applicable third party advertiser to see how your personal information will be collected, stored and used as part of their service.
Click Through URLs
Some of our Services, including email messages, use “click-through URLs” linked to other content on our Services. We track this click-through data to help us determine interest in topics and use of the Services.
Monitoring/Public Information
You may also choose to disclose personal information in our Forums. Personal information you disclose in such Forums is public information, and there is no expectation of privacy or confidentiality. Please refer to the Terms of Service for additional information relating to the disclosure of personal information in such Forums.
Other Sources
We may collect or receive information from other sources including other users of the Service and third party information providers and partners. For example, we receive and store the information you provide when you enter any promotion, sweepstakes or loyalty program. Such information may be used to supplement your account information and/or profile and may be combined with other information we collect from you.
2. Use, Disclosure and Transfer
Unless otherwise described elsewhere in this Privacy Policy, we will not use or disclose any personal information collected from you. Your personal information may be used alone or in the aggregate with information collected from other users.
Use by Company
We use the information you provide so that we may better understand your needs and the needs of our customers, prospective customers, and visitors. Specifically, we use your personal information for many purposes, including:
(a) to allow you to register for and use our Services;
(b) to apply for employment opportunities at the Company;
(c) to audit and analyze data to improve and ensure the continued smooth operation of our Service;
(d) for market research purposes, including, without limitation, to analyze user characteristics and usage patterns in order to better understand how our Services are used and market them more effectively;
(e) to communicate with you concerning your account or to send you announcements, newsletters, promotional materials and other information about our Services or offerings of our business partners, and to offer you opportunities to participate in surveys, contest and sweepstakes; *
(f) to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving our Service;
(g) to respond to inquiries, troubleshoot problems, investigate incidents, and handle complaints;
(h) provide, maintain, protect and improve our Services, including keeping you posted on our latest Service announcements, software updates and upcoming events, and develop new services;
(i) protect our rights or property or that of our users;
(j) to satisfy any applicable law, regulation, legal process or enforceable government request;
(k) to send notices, such as communications about your purchases and changes to our Terms of Service, this Privacy Policy and other Service-specific policies, and to enforce applicable terms and conditions set forth in such policies;
(l) to enable user-to-user communications; and
(m) protect against harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.
The Company processes personal information on our databases, equipment and servers (owned by the Company and/or third parties in the South Korea and in other countries). In some cases, we may process personal information outside of your country.
*If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or follow the process described in the “Opt-Out Provision” section below
Disclosure and Transfer to Third Parties
We generally do not disclose or transfer any personal information about our customers, prospects, or visitors to any third parties. We may however, disclose and transfer data which does not contain or reveal any personally identifiable information or is specifically attributable to you to our business partners, third party analytics service providers, ad networks and advertisers (collectively, “Partners”). Provided, however, some Partners may also act as third party service providers (described below) to us and may have access to your personally identifiable information. Moreover, Partners may obtain public information about you from your profile or other public sources.
We may also periodically engage in co-marketing activities, where we work with a complementary solution provider to launch a joint marketing program. In these situations, we will only send information to you on behalf of the other; we do not provide your personally identifiable information to such partner. We may also enter into business partnerships with other parties to provide specific services. If a user signs up for these services or responds to a particular marketing offer, we may share personally identifiable information such as your name or other contact information that is necessary for our business partner to provide these services or get in contact with you.
Disclosure of your personally identifiable information may occur when we engage or employ service providers, vendors or other third parties to facilitate the provision of our Services (including, without limitation, payment processing, data analysis, e-mail delivery, hosting services, customer service and promotional services) to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Such third party service provider ( “Third Party Partner”) may have access to your personally identifiable information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Currently, the name of Third Party Partner, services performed by it on our behalf, service territory of it, and period of retention and use by it of Personal Information are as follows:
In the event Company combines with another company in the future through a corporate merger, sale, acquisition, liquidation or other similar process, your personally identifiable information may be transferred with the business or a part of it, or may be sold as an asset of the business, to the successor organization in such transaction. If material changes to the Company’s privacy practices will occur as a result of such transaction, we will notify you and other users in the manner described in this Privacy Policy.
In addition, upon the expiration or a termination of any third party license arrangements involving one or more parts of the Service, your personal information (including name, email address and other personally identifiable information) may be transferred to the subject third party licensor in accordance with the terms of the applicable license agreement. In advance of such transfer to a third party licensor, the Company will notify you and other users in writing in the manner described in this Privacy Policy.
Safety, Security and Legally Required Disclosures
Your personally identifiable information, and communications you make within the Service, may be accessed and disclosed if we believe that our Service is being used in the commission of a crime, when we believe in good faith that there is an emergency that poses a threat to the safety of you or another person and when necessary either to protect our rights or property including to enforce our Terms of Service, or for us to render the service you have requested.
We may also disclose personally identifiable information when required by law, regulation, court order, or in response to a subpoena or litigation discovery request, or in the good faith belief that such action is necessary in order to conform to the edicts of the law or comply with a legal process served on us. In addition, we will make any legally required disclosures to government authorities and provide notice to you of any breach of security, confidentiality or unauthorized release of personal or private data in accordance with applicable laws, rules and regulations.
3. Storage and Security
We employ reasonable measures (both online and offline) to protect the security of information we collect from you. Such information is housed in secure databases, equipment and servers located in the South Korea and/or in other countries. The databases, equipment and servers we utilize may be owned by third party providers. To prevent unauthorized access, loss, or misuse, maintain data accuracy, and ensure the appropriate use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we maintain. We use industry-standard technology, such as firewalls, in an effort to protect the confidentiality of your personal information. Moreover, in addition to password protection offered in connection with your Service account, we encrypt your transmission of sensitive information to us (e.g., account passwords and payment-related identifiable information) via SSL (secured socket layer) protocol in the interest of heightened privacy protection and information integrity.
Although we take reasonable precautions against possible security breaches of our Service, databases, equipment or servers, and records, we cannot guarantee that unauthorized access, hacking, data loss, or other security breaches and factors beyond our control will never take place and result in disclosure of your personal information. Accordingly, we disclaim any guarantees, warranties or representations relating to maintenance or nondisclosure of any personal information collected from you. We strongly urge you to take reasonable measures at all times (online and offline) to protect your personal information, including your password and other sensitive information.
In addition, while we strive to protect your personal information, you should know that information sent over the Internet, whether by e-mail or by using one of our on-line forms, is not necessarily secure against interception. Therefore, we cannot be responsible for such interception and cannot guarantee the security of such information.
We will investigate, attempt to resolve and take all reasonable steps necessary to ensure that your personal information and data is treated securely and in accordance with this Privacy Policy.
We will retain your personal information for as long as is necessary to fulfill the purposes for which it was collected or as needed to provide you with Services. We may retain your personal information after you have closed any account you have with us or after we have ceased providing Services to you if retention of your Personal Information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between members, prevent fraud, cheating or abuse, or enforce this Privacy Policy or any other agreement we may have with a user.
4. Additional Privacy Policy Terms
Opt-Out Provision
When we first collect information from you, we will offer you the opportunity to opt-out of having your personal information shared with parties outside of Company (unless otherwise described in this Privacy Policy). In addition, if you do not want us to send you communications relating to our Services, including, without limitation, announcements, newsletters and promotional materials or offers to participate in surveys, contests or sweepstakes, you can opt-out at the time of registration or information collection. If, at a later date, you choose to have your name or any other personal information removed from our mailing list, you can do so by emailing ([email protected])
Review, Update, Correct, or Delete Personal Information
Generally, you may review, update, correct or delete your personal information collected by or through our Service by logging into your account. You may also correct factual inaccuracies. Certain types of personal information that is necessary to check eligibility, such as birth date or age, cannot be deleted, but may be modified with sufficient verification of the new information. Note that we reserve the right to terminate or delete any registration or promotional entry if we believe the personal information submitted was knowingly false or fraudulent.
To delete your personal information, you may also email us at ([email protected]). We will use commercially reasonable efforts to honor your request.
Please be aware that even after your account is terminated or deleted, some or all of your information may still remain visible to others, including but not limited to any information that has been: (i) incorporated into others user’s content, comments, postings, submissions, cities, resources or other in-game assets; (ii) copied, stored or disseminated by other users; (iii) shared or disseminated by you or others such as in a public posting; or (iv) posted on a third party platform. A request to delete and/or termination of your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us. We are not able and/or obligated to remove any of your information from a third party platform.
Moreover, please be aware that even after you delete your account or your account is terminated, your information is not deleted in its entirety from our servers and may not be deleted from servers of the third party platform you use to access our Services. We may, but are not obligated to, retain backup copies of your information, including personal information on our servers or databases (and/or any authorized third party servers or databases we use). Such information may be disclosed pursuant to this Privacy Policy regardless of whether your account is deleted or terminated. Moreover, any third party platform that you use to access the Services may also retain backup copies of your information even after your account is deleted or terminated which may be used and/or disclosed in accordance with their privacy policy.
To have access to your personal information, you must provide proof of identification such as full name, street address, city/state and zip code, user ID and password, and/or information about your recent activity on our Service. We reserve the right to deny access to any user if we believe there is a question about your identity. And if the burden or expense of providing access to your personal information is disproportionate to the risks to your privacy, or if the legitimate rights of others would be violated, we may decide not to provide access to such information. Moreover, we may still retain an archived copy of your information in our files as required by law or for legitimate business purposes, including, resolving disputes, enforcing the Terms of Service, and for other technical and legal requirements and constraints related to our Service.
To manage the information, we receive about you from the SNS where you play our games, you will need to follow the instructions at that SNS for updating your information and changing your privacy settings.
Notification of Changes
We reserve the right to update and change the terms of this Privacy Policy at any time. If we decide to update and materially change the terms of our Privacy Policy, we will post those changes in our Services and/or on the applicable Sites, and in the updated Privacy Policy. You should periodically check this Privacy Policy for updates.
By continuing to access or use the Services after we have posted an updated Privacy Policy or have provided you with notice of a modification, you are agreeing to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.
Links to Third Party Websites, Services and Offers.
Our Service may contain links to other websites, services and/or offers from third parties. We are not responsible for, nor will it be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information you voluntarily chose to provide to them. You should review the applicable privacy policies and information practices of such third parties carefully before providing personal information to them. Moreover, if you have any questions or concerns, you should contact the third party directly.
Users Outside South Korea
The Company is a South Korea company and Company’s business operations are primarily conducted in South Korea. We operate our company and administer this Privacy Policy under applicable laws and regulations of the Republic of Korea(“South Korea”). If you use our Service from outside South Korea, you are thereby consenting for your personal information to be transferred to, stored in and be processed in the South Korea and/or in other countries by the Company and/or its Affiliates in the manner described in this Privacy Policy. Your consent to this Privacy Policy followed by your submission of your personal information represents your agreement to such transfer, storage and processing of information.
As described elsewhere in this Privacy Policy, when you submit personal information via our Service, the information is housed in secure databases, equipment and servers located in the South Korea and/or in other countries. The databases, equipment and servers we utilize may be owned by third party providers.
Users in certain jurisdictions may have a right to access his/her personal information held by the Company and/or its Affiliates. Your right of access to such personal information can be exercised in accordance with applicable laws, rules and regulations. Please submit any requests for such access to ([email protected]).
Language
The controlling language of this Privacy Policy is English. If you have received a translation into any other language, it has been provided for your convenience only. The English version of this Privacy Policy shall govern to the extent of any inconsistency between the English version and any translated version.
Contact Us
If you have any questions, inquiries, requests, complaints, or comments regarding this Privacy Policy, or have other questions or suggestions about our information practices, please contact us via e-mail at ([email protected]).
© Gravity Co., Ltd. All rights reserved.
PRIVACY POLICY (For EU and UK Residents)
(Effective Date: June 29, 2023)
1. Introduction
We take privacy seriously, and we are committed to protecting personal data (the “Personal Data”) of our users (“you” or “User”) who reside in the territory of the European Union (EU) which includes the European Union member states and Iceland, Liechtenstein, and Norway. This policy also covers our users who reside within the United Kingdom.
This Privacy Policy (the "Policy”) is based on the principles set forth under the General Data Protection Regulation (GDPR) (and any other applicable law mandating data protection/GDPR) and describes the full scope of purposes and reasons for collecting and processing of Personal Data. This privacy policy also determines and limits what Personal Data we collect and how we use it (several sections below), how long we store it (is covered in each section devoted to the specific data), who has access to it, and what rights and other control mechanisms are available to you as a User.
This Policy applies where we are acting as a data controller concerning your data and is limited to data collected or received by us through your use of our Services (defined hereinafter).
2. Who We Are
Gravity Co., Ltd ("Controller"), with Controller’s affiliates and independent contractors (“Co-Providers”, collectively with Controller, "us," "our," or, "we"), provide mobile game named WITH (Whale In The High) (“Game”) and related services, including, without limitation, online communities for Game or social network services offered by us via https://community.withhive.com/withglb/en (collectively, our “Service(s)”). For clarity, the specific list of Controller’s affiliates and Co Providers are as followed.
| Name |
Address |
Role |
| Gravity Co., Ltd. |
D Tower 15F, Nuritkum Square, 396 Worldcup Buk-ro, Mapo-Gu, Seoul, Korea |
Publisher |
The Services for our Game includes Sites, without limitation, such as online communities for Game or social network services offered by us via https://community.withhive.com/withglb/en. The specific list of our Sites are as followed.
The Personal Data is processed by:
Company Name: Gravity Co., Ltd.
Official Address: 15F, 396, World Cup buk-ro, Mapo-gu, Seoul, South Korea (Sangam-Dong, Nuritkum Square R&D Tower)
Phone: 82-2-2132-7000
Contact Email: [email protected]
The EU Representative of Controller under EU GDPR can be reached at:
Company Name: The DPO Centre (Europe) Ltd.
Official Address: Alexandra House, Ballsbridge Business Park, Ballsbridge Park, Merrion Road, Dublin, Ireland, DO4 C7H2
Phone: +353 1 631 9460
Contact Email: [email protected]
The UK Representative of Controller under UK GDPR can be reached at:
Company Name: The DPO Centre Ltd.
Official Address: The DPO Centre, 50 Liverpool Street, London, EC2M 7PY, UK
Phone: +44 (0) 203 797 1289
Contact Email: [email protected]
Further, our data protection officer can be reached at:
Name : Gravity Co., Ltd.
Email : [email protected]
Address : 15F, 396, World Cup buk-ro, Mapo-gu, Seoul, South Korea (Sangam-Dong, Nuritkum Square R&D Tower)
3. Processing of Personal Data
We process your Personal Data when they are strictly necessary for the following purposes:
3.1 Performance of our Services
We process, if any, your Personal Data on the lawful basis of performance of the agreement concluded between you and us in order:
• to provide our Services to Users namely: registration (creation) and operation of Game account, providing access to the Game account, formation and performance of the agreement with us on using the Services, providing the Game, the Services and Game access to Users, sending, processing of and responding to support tickets along with other communications with us, payment acceptance;
• to enhance the security and safety of your Game accounts;
• to communicate with you about transactions made by you while using our Services or Game, as well as to send you notifications related to your account security such as notifications about password recovery requests, editing security settings, changing of e-mail or profile settings and similar;
• to send you information about updates in our Services or Game, about features on our Sites, about upcoming events (online and offline) and other information related to our Services or Game (in case you have not unsubscribed);
• to inform you about changes in our policies and legal documents;
• to communicate with you to resolve any problem you faced while using our Services or Game;
• to inform you about our activities (in case you have not unsubscribed); for developing new tools, products or services for you;
• to provide support, as well as technical support, including, but not limited to, Game and Services updates, product patches and fixes and other similar communications;
• to restore access to the User’s account, Services and/or to the Game;
• to restore lost payments made by the User
• to improve our Services and Game, as well as while requesting your feedback about our Services and Game;
• to provide you with information, Services, and the Game available at or intended for the territory where you are;
• to send notifications or communications related to access to Our Services and/or the Game, password restoring or otherwise restoring access to the User’s account. You can disable this feature at any time, though you will be unable to use such features.
For these purposes, we process, if any, the following Personal Data:
• Compulsory Data that is processed in all events:
º User’s ID in the social network that is used for registration at Game (if applicable)
º correspondence with User, including support tickets along with other communications;
º IP address and other online identifiers of User’s devices and applications
Compulsory Data is required for us to provide Services and the Game to Users and perform other obligations under the agreements concluded with Users. Request for erasing of such data may result in your inability of using our Services as set forth in below.
Compulsory Data may be collected through, namely:
• through registration with Services and/or with the Game;
• while contacting us via e-mail, phone or mailing address of ours;
• while contacting our support team or otherwise;
• while using the forum, chats related to Services and/or the Game;
• while using Services and/or the Game otherwise (including information you provide to when participating in competitions, contests, and tournaments or responding to surveys, e.g. your contact details);
We also process anonymous data to analyze and produce statistics related to the habits, usage patterns, as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. Anonymous data, may be shared with third parties.
If we find that you provided incorrect or inaccurate Personal Data, it may restrict (ban) your Game account until you amend it.
3.2 Payment
When the User tops up his or her Game account or makes payments via application market such as Google Play or App Store (the “App Markets”), we and the App Markets that is chosen by the User to process the payment may, if any, exchange with the following Data:
- user ID from our billing system
- user ID in the payment system
- payment (transaction/order) ID
- date and time of payment (transaction/order)
- amount of payment (transaction/order)
- the currency of payment (transaction/order)
When the User use credit cards for payment purposes, the Data, if any, required by App Markets are:
- name of the cardholder;
- masked card number - 6 symbols and last 4 digits;
- country code (if applicable);
- address (if applicable).
Such Data regarding credit card payment as mentioned is provided by the User directly to the payment systems under the terms of use of such system that the system may require Users to enter before processing the payment. We do not process such Data.
3.3 Promotion
We process, if any, Personal Data on the lawful bases of consent and legitimate interests pursued by us or a third party (e.g., the interests of other customers of ours), except where such interests are overridden by your prevailing data protection rights and if you have withdrawn your consent, to send promotional or marketing information and news about the planned contests, promotions and similar events, news about our Services and the Game.
If you do not wish to receive such information, you can unsubscribe from receipt of such information following the instructions as described in the corresponding messages or Game account interface.
We also process Personal Data on the same lawful basis in order to manage Users’ relationships and organization, follow-up, communication, subscription and invitations relating to competitions, events or game tournaments organized or supported by us (for example, communication with you when you take part in online or offline competitions, events or game tournaments organized or supported by us or arrange your travel, receipt of gifts and awards, to which you may be entitled as a result of winning in online or offline competitions or events, etc.).
The scope and purpose of the processing of your Personal Data, among other conditions for the processing, is specified in this Policy. We will notify you about any changes in our Policy.
Process of Non-Personal Data for improvement and development
To provide quality Services and to justify your expectations of Our Services and/or Game, we collect, if any, anonymous data:
- name and version of the operating system,
- the size of RAM
- the size of available disk space
- parameters of the network channel and internet connection such as network bandwidth and delay from User’s mobile devices to our servers, traceroute information between your mobile devices and our servers, etc.
- other data that is mentioned in the Technical requirements to the Game
We collect information about your Game' preferences, progress in Game, playtime, as well as information about device settings, unique device identifiers, and crash data. We process and store such data also to evaluate development plans, provide updates to the Services and Game, bug-fixing.
Such information, is stored for the validity period of relevant agreements with us and 1 year after the termination of such agreements unless there is a legitimate reason for a longer processing.
Be also aware, that for the purpose of organization of game process, we collect information about your in-game activities, logs, and data on in-game transactions. Such data also used for Game violations detections (as well as Sites violations) to prevent or punish for cheating and unfair gaming behavior. This data is used for detection, investigation, prevention and, where applicable, and stored only for the minimum amount of time needed for this purpose. If the data indicates that a violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such violations. Also be aware that enjoying a certain User’s rights shall be in balance with rights and interests of other Users and should not affect the rights and freedoms of other parties.
3.4 Prevention of illegal behavior
We process your Personal Data on the lawful basis of compliance with legal obligations that we are subject to in order:
• to prevent the illegal use of our Services and the Game if there is reason to believe that there is a risk to security of Our Servers (i.e. blocking of concurrent IP addresses).
For this purpose, the Data processed is:
- IP address and other online identifiers,
- browser or device identifiers,
- operating system,
- crash data.
• to prevent illegal user’s access
For this purpose, the Data processed is:
- the organization of the game process,
- information about your in-game character activities, logs, and data on in-game transactions,
- Game data and commands the so-called log files (information on the actions made by the character in the Game generated by the software, fixed in symbolic non-personal form),
- the content of in-game chats (correspondence).
We use this data for decisions to ban a Game account or user’s character, according to the rules of the relevant Game.
In the event of litigation between the User and us or in case we receive a request from competent authority, such data can be combined with the personal information you provide and are stored during the period of resolution of the dispute.
4. Security Measures
Our endeavors to implement technical and organizational measures to protect your Personal Data against accidental or unlawful destruction, alteration or loss, unauthorized disclosure, or access. We, affiliates and third parties authorized to access the Personal Data, are required to give the undertaking to maintain such confidentiality and secrecy.
Among other measures, any information sent to us is encrypted (scrambled) using high qualified technology. This is industry-standard encryption technology that protects your data while being sent over the Internet from being intercepted and misused by third parties.
We have put in place, and regularly reviews and updates, appropriate physical, electronic, and managerial procedures to keep the data safe and help prevent unauthorized access, maintain data security and correctly use the information collected.
Should we become aware of a data breach we will take all relevant actions and steps necessary to rectify the breach. We will also notify the relevant supervisory authority and individuals (if required under the GDPR and other applicable data protection laws) and work with other parties as required to ensure any breaches are remedied and there is no other compromise of personal data.
5. Sharing of User’s information
We do not transfer your data to anyone, except for those specified in this Policy or as provided by the rules into force. This is related to the provision of Our Services and performance of contracts you have concluded with us. If such transfer to third parties is related to any other purpose, we will notify you of such transfer.
We do not sell your personal information and does not receive benefits from any treatment of your data. We do not use your data for advertising or promotion of products and services of third parties.
(1) Regarding Payment systems, we share your Personal Data such as:
Email address, IP address, information about in-game purchases, and other information you provide to us for the purpose of fulfilling your purchase. The list of payment methods (payment systems, payment agents) that may be used by the User for payments and with which we may share your data are described at our Sites. The specific list of the entities who access the Personal Data to process the payment, the place where the transferred Personal Data is stored and the relevant contract name based on which the Personal Data is transferred are as followed.
(2) With data storage partners, we share your Personal Data
Some of the information is stored using third-party data storage services. We provide personal information to our affiliates and other trusted businesses or persons to process it for us, in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. The specific list of the entities whose information storage service is used for the custody of Personal Data, the place where the transferred Personal Data is stored and the relevant contract name based on which the Personal Data is transferred are as followed.
The data is stored separately. Your data may be combined with other data collected by us in exceptional cases, for example, in case of a violation by users of the agreement with us or the rules of the game, the availability of a dispute between us and the User, conduct of financial control and accounting, etc. As for the detecting violations, be aware that we use anti-cheating tools that collect information about the processes in use while you are accessing Game.
The User can modify and/or erase the data provided to them, except for those specified in this section as unalterable. The user may edit his personal information having access to his private account. All changes are logged.
(3) For publicly available information
Our Sites may also have, if any, message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum, or chat area, please be aware that the information is being made publicly available on-line; therefore, you are doing so at your own risk. If your personal information is posted on one of our community forums and you want to remove such information, please inform us with request to its removal.
(4) With Anti-cheat and anti-fraud companies,
We share the information required for our detection, investigation, and prevention of cheating in the Game and violations of agreements related to the Game only for the purposes of detection, investigation, and prevention of cheating in the Game.
(5) When our control is changed
We may share your data as part of our company’s sale, merger or change in control, or preparation for any of these events. Any entity which buys us, or part of our business will have the right to continue using your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.
6. Retaining and Deleting Personal Data
We retain, if any, your Personal Data only for the period of time as necessary to achieve the particular purpose for which the information was processed. Typically, without your request to erase Personal Data and also without legitimate reason to keep it longer, after the termination of our relationship, we retain your information for 1 month after deregistration of your Game Account or for the duration described in the table below:
| Personal Data Retained |
Retention Period |
|
Data necessary for performance of the agreement or cancellation of subscription
Records of payment
Tax and accounting records
Records of electronic financial transaction
|
5 years |
|
Records of a customer complaint or dispute resolution
Records that Game account or character was banned based on the violation.
|
3 years |
|
Records of correspondence with User for statistics purposes; to
deliver, develop and improve our Service and the Game; to
support Users in using the Services and the Game; to
ensure security and confidentiality of the User’s account and data; to
restore access to the User’s account, Services and/or to the
Game; to restore lost payments made by the User.
Record of User’s Game' preferences, progress in Game,
playtime, as well as information about device settings, unique
device identifiers and crash data.
|
3 years |
|
Record of in-game character activities, logs, and data on in-game transactions,
log-files and in-game chats.
Records of misuse by users of Game or Services
|
3 years |
|
Computer communication or internet log-in records of
computer communication or facts about an internet user’s
utilization of telecommunication service
|
3 years |
|
Record of IP address and other online identifiers
|
3 years |
|
Log-files and chat in case of dispute with the User
|
The duration of the dispute |
For the clarity, we retain your information insofar as such information will be processed solely for archiving purpose in the compliance with our legal obligation or statistical purposes, subject to appropriate safeguards, in accordance with the data protection laws, for your rights and freedoms. The appropriate safeguards shall ensure that technical and organizational measures are in place to ensure respect for the principle of data minimization.
7. Our Policy Concerning Children
You must be at least 16 years of age to use our services and we do not knowingly collect any personal information from children under the age of 16 years old. If a child under 16 years old and would like to make use of our services (i.e. download and play the game we are offering) parental/legal guardian approval (i.e. consent) is required. We will take reasonable efforts to ensure we gain approval from a parent/legal guardian by taking the below steps:
1. When the app is downloaded those who are under 16 years old will need to provide a parents/legal guardians email address where required
2. Once sent to us we will send an email asking approval (i.e. parental/legal guardian consent) for someone under 16 to use our services
3. Once we receive approval from a parent/legal guardian for those under 16 years old, they can start making use of our services
4. If a parent/legal guardian rejects approval our services cannot be used
Gravity Co., Ltd. is not responsible for those who have falsely claimed to have gained parental/legal guardian consent. If we discover a child under 16 years old has not gained parental/legal guardian consent, we will take all reasonable measures to delete their information from our systems which may also result in banning them from using our services again.
You can contact us at [email protected] and [email protected] to inform us if you suspect someone under 16 years old is using our services and has not gained parental/legal guardian consent at any time.
8. Your Privacy Rights
(1) Right to Access
You are entitled to confirmation as to whether or not we process your Personal Data and, where we do, access to the Personal Data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Data concerned, and the recipients of the Personal Data. We will supply you a copy of your Personal Data. You can access your Personal Data by logging into your Game account or contacting us using our details listed above.
(2) Right to Rectification
You are entitled to have any inaccurate Personal Data about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about you completed. You may change or update the profile information by logging into your Game account or by contacting us using our details listed above.
(3) Right to Erasure
In some circumstances, you are entitled to the erasure of your Personal Data without undue delay. Those circumstances include: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing; (iii) you object to the processing; (iv) the Personal Data must be erased to comply with a legal obligation and (v) the Personal Data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: (a) for exercising the right of freedom of expression and information; (b) for compliance with a legal obligation; (c) for public interest or (d) for the establishment, exercise or defense of legal claims.
If you choose to terminate or delete your Game account, we will immediately delete your Game account information.
If a User requests the erase of the Personal Data, while a prior request (s) from that User is still being processed, such data can be erased only when the User has recalled/canceled all previous requests.
You may request the erasure of your information by visiting the Sites or by contacting us using our details listed above.
(4) Right to Restrict Processing
In some circumstances, you are entitled to restrict the processing of your Personal Data. Those circumstances are: (i) you contest the accuracy of the Personal Data; (ii) processing is unlawful, but you oppose erasure; (iii) we no longer need the Personal Data for the purposes of our processing, but you require Personal Data for the establishment, exercise or defense of legal claims; and (iv) during the verification of the prevalence of the legitimate interest that we pursue regarding the Personal Data processing on yours. Where processing has been restricted on this basis, we may continue to store your Personal Data. However, we will only otherwise process it: (a) with your consent; (b) for the establishment, exercise or defense of legal claims; (c) for the protection of the rights of another natural or legal person; or (d) for reasons of important public interest.
You may request the restriction of the processing of your information by visiting the Sites or by contacting us.
(5) Right to Object to Processing
You have the right to object to our processing of your Personal Data, at any time, on grounds relating to your particular situation, but only to the extent that the lawful basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You may object to the processing of your information by visiting the Sites or by contacting us using our details listed above.
(6) Right to Object to Processing for Direct Marketing Purposes
You are entitled to object to our processing of your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your Personal Data for this purpose.
You may object to the processing of your information for direct marketing purposes by visiting the Sites or by contacting us using our details listed above.
(7) Right to Object to Processing for Statistical Purposes
You have the right to object to our processing of your Personal Data for statistical purposes. We do statistical processing for analyzing game data for analysis and optimization of the service and advertising campaigns which can include the user’s device or IP information.
You may object to the processing of your information for statistical purposes by visiting the Sites or by contacting us using our details listed above.
(8) Right to Data Portability
To the extent that the lawful basis for our processing of your Personal Data is:
• consent; or
• that the processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract, and such processing is carried out by automated means, and you have the right to receive your Personal Data from us in a structured, commonly used and machine-readable format and the right to have your Personal Data transmitted to another controller.
You may request to receive your information by visiting the Sites or by contacting us at using our details listed above.
(9) Right to Complain to a Supervisory Authority
If you consider that our processing of your Personal Data infringes data protection laws, you are entitled to file a complaint with a supervisory authority responsible for data protection.
You can find more details of the supervisory authority in your country by visiting
https://commission.europa.eu/index_en
For the UK: https://ico.org.uk/make-a-complaint
(10) Right to Withdraw Consent
To the extent that the lawful basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may withdraw your consent at any time in the Game setting or contacting us at using our details listed above.
You may also exercise any of your rights concerning your personal data by written notice to us at using our details listed above.
(11) The right to not be subject to automated decision-making
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
9. Change/Update to Privacy Policy
We may amend, at our discretion, any portion of this Privacy Policy at any time by posting or displaying the amended Privacy Policy within and/or on the Sites. We request your reading confirmation for each of these amendments. Except as otherwise stated, any such amendments will be automatically effective after they are initially posted. We will notify you about any significant changes in our Policy. This policy was last updated on June 29, 2023
10. Links
The Service may contain links to other websites. The fact that the Service links to a website or presents a banner ad or other type of advertisement does not mean that we endorse or authorize that third party, nor is it a representation of our affiliation with that third party. We are in no way responsible for the privacy policies of these other websites to which you choose to access from the Services. It is your responsibility to read the privacy policies of these other websites when exiting the Services.
11. Questions
If you have any questions regarding our Privacy Policy and/or practices, please email us using our details listed above.
Privacy Notice for California Residents
(Effective Date: June 29, 2023)
This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who use the Service and reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
Protecting your privacy is important to Gravity, Co., Ltd. and its subsidiaries and affiliates (“Gravity,” “we,” “our,” or “us”) because we know how important it is to you. This Privacy Notice describes the information that we collect through websites that we operate (each, a “Site”), our game publisher networks, crowd-sourcing service, and platforms (each, a “Network”), any mobile and web application of ours (each, an “App”), and chat rooms, blogs, web forums, messaging boards, or other public forums in our Apps and Sites (each, a “Forum”); how we use, disclose, and protect your information; and the choices you can make regarding your information. The Sites, Networks, Apps, and Forums are referred to herein, collectively, as the “Service.”
1. INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, through your use of the Service, we have collected the following categories of personal information within the last twelve (12) months:
| Category |
Examples |
Collected |
| Identifiers |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers |
YES |
| Personal information categories listed in Cal. Civ. Code § 1798.80€ |
A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information |
NO |
| Protected classification characteristics under California or federal law |
Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) |
NO |
| Commercial information |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
NO |
| Biometric information |
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data |
NO |
| Internet or other electronic network activity information |
Browsing history, search history, and information on a consumer’s interaction with an Internet Web site, application, or advertisement |
YES |
| Geolocation data |
Physical location or movements |
NO |
| Sensory data |
Audio, electronic, visual, thermal, olfactory, or similar information |
NO |
| Professional or employment-related information |
Current or past job history or performance evaluations |
NO |
| Non-public education information |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records |
NO |
| Inferences drawn from any of the information identified above |
Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
NO |
Personal information does not include:
• Publicly available information from government records;
• De-identified or aggregated consumer information;
• Information excluded from CCPA’s scope, like personal information protected by other certain sector-specific federal or California statutes.
2. HOW WE COLLECT PERSONAL INFORMATION
We obtain the categories of personal information listed above from the following categories of sources:
• Directly From You: The information you provide while using the Service.
• Indirectly From You: We collect certain technical information, like the Internet Protocol address, when you access and use our Service.
• Collected and/or Received From Third Parties: We may collect your data from third parties, such as when processing your purchases through our Sites or Apps or when you access our Service through a social networking service (“SNS”).
• Collected Through Mobile Devices: When you use our Apps on your mobile telephone or other mobile device (“Mobile Device”), you are authorizing us to collect, store, use, and/or share, in addition to the information described above, the Mobile Device type; mobile carrier; platform version; navigation, interaction, and engagement information regarding our users; and other information you choose to provide to us. Also, we receive and store information you provide when you sign up to have Short Message Service (“SMS”) notifications sent directly to your Mobile Device.
3. HOW WE USE PERSONAL INFORMATION
We may use the personal information we collect for one or more of the following purposes:
• To fulfill or meet the reason you provided the information;
• To provide, support, personalize, and develop our products and services for and through our Service;
• To create, maintain and service accounts;
• To provide customer service;
• To process your requests and payments and fulfill orders and transactions;
• To verify consumer information;
• To personalize your Site, App, and Forum experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Service and via email or text (with your consent, where required by law);
• To provide advertising and marketing services;
• To provide analytic services;
• To detect and respond to security incidents;
• To improve our Service;
• For testing, research, analysis, and product development;
• For auditing related to a current interaction with the user and concurrent transactions, including but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your personal information or as otherwise set forth in the CCPA;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Gravity’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Gravity about our Service’s users is among the assets transfers.
Gravity will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
4. SHARING PERSONAL INFORMATION
Gravity may disclose your personal information to a third party for a business purpose. When we disclose your personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep your personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
| Category A: |
Identifiers |
| Category B: |
Personal information categories listed in Cal. Civ. Code § 1798.80(e) |
| Category C: |
Commercial information |
| Category D: |
Internet or other electronic network activity information |
We disclose your personal information for a business purpose to the following categories of third parties:
• Our affiliates;
• Our Partners
• Service providers;
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information.
5. DATA SECURITY
We have implemented measures designed to secure and safeguard your personal information from accidental loss and from unauthorized access and disclosure. We maintain physical, electronic, and managerial procedures to limit access to your non-public personal information.
Unfortunately, transmission of information via the internet is not completely secure. Although we take reasonable precautions to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our Services or other electronic means. Any electronic transmission of personal information is at your own risk.
6. YOUR RIGHTS AND CHOICES
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting that personal information;
• The categories of third parties with whom we share that personal information;
• The specific pieces of personal information we collected about you (also called a data portability request);
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
o sales, identifying the personal information categories that each category of recipients purchased; and
o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation;
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
• Visiting https://with.gnjoy.com/en
• Emailing us at [email protected]
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will use only personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
7. NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or service;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services;
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
8. OUR POLICY CONCERNING CHILDREN
You must be at least 13 years of age to use our services and we do not knowingly collect any personal information from children under the age of 13 years old. If a child under 13 years old and would like to make use of our services (i.e. download and play the game we are offering) parental/legal guardian approval (i.e. consent) is required. We will take reasonable efforts to ensure we gain approval from a parent/legal guardian by taking the below steps:
1. When the app is downloaded those who are under 13 years old will need to provide a parents/legal guardians email address where required
2. Once sent to us we will send an email asking approval (i.e. parental/legal guardian consent) for someone under 13 to use our services
3. Once we receive approval from a parent/legal guardian for those under 13 years old, they can start making use of our services
4. If a parent/legal guardian rejects approval our services cannot be used
Gravity Co., Ltd. is not responsible for those who have falsely claimed to have gained parental/legal guardian consent. If we discover a child under 13 years old has not gained parental/legal guardian consent, we will take all reasonable measures to delete their information from our systems which may also result in banning them from using our services again.
9. CHANGES TO OUR PRIVACY NOTICE
Gravity reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this privacy notice, we will update the Privacy Notice’s effective date, and notify you via email at the last email address that you provided us and post the updated notice on the Sites. Your continued use of our Service following the posting of changes constitutes your acceptance of such changes.
10. CONTACT INFORMATION
If you have any questions or comments about this Privacy Notice, the ways in which Gravity collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
• Visiting https://with.gnjoy.com/en
• Emailing us at [email protected]