The data controller for the purpose of data protection law is: Nexon Korea Corporation, 7, Pangyo-ro 256 beon-gil, Bundang-gu, Seongnam-si, Gyeonggi-do, Korea, 463-400, also referred to herein as “NEXON”, “we” or “us”. Please feel free to address any questions or concerns regarding data protection/privacy to email@example.com.
You may be able to access third party services (including through links, advertisements, or other means), including social networks, such as Twitter, Facebook, and Google+, from our Applications. When doing so, please understand that those third parties have their own set of information practices. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third parties.
Declaration of Consent
§ The collection, storage, use and processing of your non-truncated IP address, MAC address and unique device identification ID by NEXON, for the purposes of providing and improving the game services, as stated in detail below in this paragraph: The information is used to monitor traffic on our websites and through our Applications, to troubleshoot technical problems and authenticate users' entitlements to our products, enforce our Terms, identify and fix software errors, should these occur, and to authenticate your software, verify license rights, to determine the applicable tax rate, to fulfill your requests, to provide advertising that is tailored to your interests, to analyze usage and performance of and improve our products and services, to provide software updates and dynamic content, to determine advertising conversion rates and otherwise provide services to you.
§ The sharing of your Personal Information with third party service providers to the extent required for them to help us provide or improve the Applications.
§ The consolidation of Personal Information (as defined below in Section 11) with technical information about your system and hardware, to ensure that the Application works properly, for internal analysis, and to improve NEXON's services, resolve errors, to communicate with you, to enforce our Terms, to prevent fraud, to manage customer loyalty programs, to personalize your experience within the Applications and NEXON's services, and to provide you with satisfactory customer service.
§ NEXON collecting, storing and using your contact information and social network profile information in order to send invitations to your social networking friends on your behalf when you use the according functionalities of any NEXON product or service.
§ NEXON sharing your game-related information, such as game ID and nickname, with third parties for the purpose of implementing and managing game-related events.
§ NEXON collecting and storing your location data and using it to provide location-based matching services.
§ NEXON sharing your profile, which will have your username and profile picture, as well as information about your uses and interactions with our Applications, for example your game results, scores, and profile information, with providers of social media sites to the extent you connect your accounts with our Applications.
§ The storage of all personal data that is collected, stored, used and processed according to this contract in the United States of America - complying with the Safe Harbor Principles -, the European Economic Area, South Korea, and/or Japan.
You know and agree that South Korea and Japan are countries in which there are no regulations in place granting an equal level of data protection as in Germany.
Of course, you can withdraw your consent at any time by terminating your NEXON Account (if you have such account) and ceasing use of NEXON's services. You may also revoke your consent in writing to NEXON Korea Corporation, 7 Pangyo-ro 256 beon-gil, Bundang-gu, Seongnam-si, Gyeonggi-do, Korea, 463-400, or by sending an email to firstname.lastname@example.org.
Table of Contents
2. Types Of Information We Collect
3. How We Collect Information About You
4. How We Use The Information We Collect
5. Sharing Of Your Information
6. Your Choices
7. Security Of Your Information
9. Deletion/Rectification of Data
10. Contact Us
1. Information Practices Concerning Children
Our Applications are not directed to children under the age of 14 and we do not knowingly collect Personal Information from children. If you are under the age of 14, please stop using our Applications. It is our policy not to knowingly solicit or permit children under the age of 14 to provide their Personal Information for any purpose.
We encourage parents and guardians to take an active role in monitoring their children’s use of the Applications. In the event that we learn that we have inadvertently collected Personal Information from children under the age of 14, we will make efforts to promptly delete the information.
In part subject to your consent, we collect the following information, including both Personal Information and non-Personal Information:
· Information We Collect About You. When you use our Applications, we may collect and store information from you directly. For example, when you register with us, we may collect certain information from you, including your name, email address, username, nicknames and passwords, and social networking and open market usernames and information, including profile pictures. Once registered, you may also have the option of completing a user profile.
When you contact us, we also collect certain Personal Information in order to be able to respond to you.
· Your Contacts. We offer you the ability to locate, invite, and play games with your contacts. To do so, NEXON may request access to your address book or social networking accounts. We will ask you for your permission before we access and store your contacts.
· Your Device Information. When you use our Applications on your mobile devices, such as a phone or tablet, we may collect information regarding your devices, including your mobile unique device identifiers and Internet Protocol (IP) address. We may also collect the name you have designated for your device, the device type, the name of your mobile network and mobile provider, and the country from which you connect.
· Your Location. If you choose to use the location-based matching feature available in some of our Applications and give the Application the necessary permissions on your mobile device, we track your location.
· Technical and Usage Information. When you use our Applications, we collect technical and usage information such as your browser type, browser language, referring and exit URLs, platform type, interactions with other users, and usage statistics with the Applications, such as connection times and download records. For more information on how we utilize log files and cookies, please see Section 3, “How We Collect Information about You.”
· Download and payment information: We collect information on what games you download and payments you make to us.
We may collect information about you, your device, and your usage in a number of ways:
· When Provided Directly from You. As mentioned above, we collect information about you directly from you in certain circumstances, including:
o Account registration;
o Contest registration and prize acceptance;
o Customer support and/or technical service requests;
o Player match up and other head-to-head online competitions;
o Registration for games and/or special game-specific events;
o Newsletter subscriptions, referral services, and other marketing surveys and email campaigns;
o Creation of a personal profile;
o Product, service and/or subscription orders;
o Service requests from third party service providers made available to you as part of our Applications;
o Your accessing our products and/or services on social networks or other third party services; and
o Otherwise through use of our Applications and other online services where personal information is required for use and/or participation.
· When Communicated or Shared with Other Users. You may also participate in certain activities on our Applications that give you the opportunity to voluntarily communicate or share information with other NEXON users, such as Posting messages on a message board, Posting public comments to user profiles or games, sending private messages, sending invitations, and Posting photos. We may monitor, record and store these communications (except for any communication by private message) in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend NEXON’s rights and property. You consent to the recording, storage and disclosure of such communications you send or receive for these purposes.
· Through log files, cookies, and similar technological means. When you use our Applications, NEXON may collect information about your use and interaction with those Applications. The bulk of this information is collected and stored through the use of technological means like cookies, log files, and analytical measurements and tools.
o Log files are small files that typically contain IP addresses. An IP address is a numeric address that may be assigned to your computer by your Internet Service Provider. In general, we use log files to monitor traffic on our websites and through our Applications, to troubleshoot technical problems and authenticate users' entitlements to our products. In the event of user abuse of our websites or Applications, however, we use IP addresses or game system IDs provided by our licensed hardware manufacturers to exercise our right to block access to our websites or Applications. If available, IP addresses and game system IDs may be used in order to enforce our Terms
o We may also make use of the following analytic metrics tools to collect information when you use our games, services, and Applications: 5 Rocks SDK, AppsFlyer, Facebook SDK. You can opt out of such tracking technologies. Please refer to Section 6 (“Your Choices”) for detailed information on how to do that.
§ These tools and technologies use server log files and cookies to collect and analyze certain types of information, including IP addresses (including for purposes of determining your approximate geographic location), mobile or other hardware device ID or other device identifiers, the name of your telecommunications company, browser types, browser language, information passed from your browser (if any), referring and exit pages, and URLs, platform type, click information, information about your device, peripheral hardware, software and/or applications installed on your machine and/or device, domain names and types, landing pages, pages viewed and the order of those pages, advertising conversion rates, the date and amount of time spent on particular pages, other Internet and website usage information, game state and the date and time of activity on our websites or games, information about how your game is used, including game metrics and statistics, feature usage and purchase history, as well as unique hardware identifiers such as MAC Address, mobile unique device ID (if applicable) and other similar information. Such information will be collected to allow us to analyze Application data and our provision of services to you.
§ Use of the analytics tools identified above may require the transmission and/or storage of information about you and your activities on services and devices not controlled by NEXON.
§ 5 Rocks collects the following information:
· Device Model
· Time Zone
· OS Version
· Display Resolution
· Country Based on Network Provider
· Android ID (Android devices) / IDFV (Identifier for Vendor) (iOS devices), as applicable
· WiFi MAC Address (Android devices only)
· ADID (Advertising ID) (Android devices) / IDFA (Identifier for Advertiser) (iOS devices), as applicable
§ MAT collects the following information:
· IP Addresses
· Device identifiers (IFA and Android ID)
· Device Fingerprinting
§ AppsFlyer collects the following information:
· Click Time
· Time of Installation
· Country Code
· IP Address
· AppsFlyer Device ID
· Customer User ID
· Device Name
· Device Type
· OS Version
· SDK Version
· App Version
§ Facebook collects the following information:
· Operating system
· Hardware version
· Device configuration files
· Software name and type
· Battery and signal strength
· Device identifiers
· Device location
· Name of your telecommunications company or ISP
· Browser type
· Mobile number
· IP address
· Time Zone
§ Similarly, certain third party analytic tools identified above may allow the companies offering those tools to collect information on our websites or through our Applications for the purpose of analyzing game data. In such cases, information collected about you may be combined with information collected independently from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Such information is not subject to this privacy statement, nor is under the control of NEXON.
We may use the information we collect in the following ways:
· We use your Game ID, nickname, character name and other profile information you share to create your account, which allows you to play our games and communicate with other NEXON users;
· We use your IP address and other identifiers, including but not limited to your open market ID, and usage statistics to provide you with a customized or personalized experience;
· We use your contact information to provide you with technical support or to respond to your questions or comments;
· We use your contact information and profile information you share to identify and suggest connections with other NEXON users or to send invitations on your behalf to your social networking friends or contacts in your address book;
· We use your contact information, profile information you share, IP address and other identifiers, and usage statistics for legal purposes, for example to enforce our Terms or to prevent fraud or other illegal activities;
· We use your IP address and other identifiers and usage statistics as well as profile information you share to provide you with relevant and targeted or direct advertising from NEXON or third parties;
· We use your contact details to send you e-mails with useful updates or promotions about our Applications and other products and services;
· If you share it with us and consent to us doing so, we use your mobile phone number and/or other device information send you notifications (SMS, push, remote, or local) on your mobile device to provide you with useful information about our Applications and other products and services (to learn how you can manage the types of notifications you receive, follow the instructions under Section 6, “Your Choices”).
· We use location data only to provide you with the location-based multiplayer matching features available in some of our Applications, and not for any other purpose.
It is our policy not to share your Personal Information with third parties for their own use except with the following parties or in the following circumstances. With respect to your non-Personal Information (such as anonymous, aggregated statistical data), we may share such information with third parties for various purposes, including for the purpose of explaining our user demographics or improving the quality or delivery of our services and the marketing materials available through the Applications. Although we will not share your Personal Information with third parties for the purpose of enabling third parties to send marketing materials to you about their products or the products of others, we may use third party advertisers (including Chartboost, AdMob, and Cauly) to deliver advertising within the NEXON mobile environment. We may share your non-Personal Information, including your operating system, country location, and Applications usage information with these third party advertisers for the purposes of delivering these advertisements. If you do not want us to share your Personal Information with the third parties set forth below for particular purposes as described, please see Section 6 below, Your Choices.
· Third Party Service Providers. We may use third party service providers, such as payment gateway companies, platform service companies, and analytics companies, to help us provide or improve the Applications we offer you. We may share your Personal Information with these third party service providers to the extent required so that they may provide their services to us. Such third parties are not allowed to use such information for any other purpose.
· Social Networking Users. Your profile, which will have your username and profile picture, may be visible to other users. In addition, your social networking friends and other users may be able to see information about your uses and interactions with our Applications, for example your game results, scores, and profile information may be Posted on your Facebook Wall or on Twitter.
· Other NEXON Users. Some of your Personal Information (included in your profile and nicknames) may also be visible to other NEXON users, through the Applications or through related websites. Other NEXON users (both those who are your social networking friends and those who are not your social networking friends) may be able to view information about your uses and interactions, such as your game results, scores, and profile information.
· Legal Purposes. We may provide your Personal Information to third parties where we have a good faith belief that doing so is required by law or to cooperate with regulators or law enforcement authorities. We may also provide your Personal Information to third parties in order to protect the rights or property of a third party or NEXON, including enforcing our Terms.
· Health or Safety. We may share your Personal Information when we have a good faith belief that there is an emergency that poses a threat to the health or safety of you, another person, or the public generally.
· Game Events. For some game related events, we may share information, including your profile and nicknames, with third parties.
NEXON provides you with a variety of choices to control the use and sharing of your information, including your Personal Information.
· Notifications (SMS, Push, Remote, and Local). We will only send you notifications with your consent. You can withdraw such consent effective for the future and thereby opt out of receiving notifications by following these steps: (1) Go to Menu; (2) Settings; (3) Push “off” under “Push Notifications”. When we receive an opt-out request from you, we may send you a message confirming our receipt of your opt-out request.
· Accessing Your Contacts. We offer you the ability to locate, invite, and play games with your contacts. To do so, NEXON may need to access your address book or social networking friends lists. We will ask you for your opt in permission before we access and store your contacts.
· Cookies. You may be able to manually delete HTML cookies and set your browser to refuse HTML cookies by going into your browser’s settings. Note though that doing so may affect your experience with our Applications.
· User Profiles. You can change and update information in your user profile at any time.
· Analytic metrics tools. You can withdraw from the use of your data regarding the following analytic metrics tools using the following links:
§ 5 Rocks: http://home.tapjoy.com/info/third-party-opt-out/
§ MAT: http://www.optoutmobile.com
· Ads. Advertising associations offer methods (http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/) by which you may be able to opt out of receiving behavioral advertising.
· Personal Information. You may at any time indicate that you wish us to stop processing your Personal Information (if such Personal Information is necessary for you to have an account, you will no longer be able to use the Game and may no longer be able to use other aspects of the Service).
Although we do not represent that we follow any particular, independent code of best practices, we maintain reasonable physical, electronic, and procedural safeguards to protect your information. For example, we protect some of your information by using a firewall and Secure Socket Layer (SSL) encryption.
While we take reasonable precautions against possible security threats, there is no such thing as “perfect security” on the Internet, so we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We strongly recommend that you take steps to maximize the security of your information, such as not sharing your login information and logging out of your account after you are done using our Applications.
We store your information in the United States, the EU, South Korea, Japan as well as other territories.
To the extent your data are no longer required for the aforementioned purposes, they are deleted. If you delete your NEXON Account, your profile will be entirely and finally deleted. To the extent data must be retained for legal reasons, they are blocked and will not be available for use.
You may request disclosure regarding your personal data that we are storing. You are also entitled to have any incorrect data corrected, and you have further rights to block or delete data. Please address any requests for such matters to email@example.com or write to us at the address stated above.
“Applications” à Our communications tools, which may heretofore or hereafter be accessed by users through any medium or device now known or hereafter devised, including but not limited to communication tools such as websites, software, mobile games and applications. Unless explicitly stated otherwise, any new tools that alter or improve the current Applications shall be included in the definition of “Applications.”
“Including” à “Include,” “Includes,” “Including,” “include,” “includes,” and “including” herein mean including without limitation.
“Personal Information” à Any information concerning the personal and material circumstances of an identified or identifiable individual. This includes information like name, postal address, e-mail address or telephone number, but also usage date in some cases. Usage data are data required to use our website, for instance information about start, end and extent of website use as well as login data.
“Post” à To upload, post, create, make available, send, share, communicate or transmit.
Effective Date: [2015.09.17]