NEXON PRIVACY POLICY

Effective Date: 2018.3.12

This Privacy Policy describes how NEXON Co., Ltd. and its subsidiaries and affiliates (collectively, “Nexon”) handle and protect the information that we collect through our websites, games, mobile apps, and other interactive software products and services that we operate and that link to this Privacy Policy (collectively, our “Services”).

INFORMATION WE COLLECT

HOW WE USE INFORMATION

WHEN INFORMATION IS SHARED
COOKIES AND SIMILAR TECHNOLOGIES
YOUR CHOICES

CHILDREN
HOW WE SECURE INFORMATION

INTERNATIONAL DATA TRANSFERS

CHANGES TO THIS PRIVACY POLICY

CONTACT US

I. INFORMATION WE COLLECT

We collect information when you provide it to us, when you communicate with others, and when you use the Services. We also may collect information about you from other sources.

Information you provide to us. When you register, contact us directly, or otherwise use the Services, you may choose to provide information to us, including:

• Contact information, including name, phone number, mailing address, and email address.

• User account information, including username, nickname, password, and profile picture.

• Demographic information, including your age, gender, and country.

• Contacts from your device address book and social media accounts.

• Payment information, which our payment processors collect when you make purchases.

• Correspondence you send to us.

Communications with others. When you communicate or share information with others through the Services, including by posting photos or communicating orally or in written messages, we may access and store the contents of these communications and related information, unless such access and storage are prohibited by law. You consent to our recording, storage, and disclosure of such communications and information that you send or receive consistent with this Privacy Policy and the Terms of Service and End User License Agreement .

Use of the Services. We collect information when you use our Services, including your Internet protocol (“IP”) address and other identifiers that are assigned to your device and application when you access the Internet or use the Services, browser type, browser version, browser language setting, operating system, device name and type, MAC address and other device identifiers, information from your device (including information from and about your hard drive and other storage devices, central processing unit, random access memory, video card, and peripheral hardware, software and applications installed on your device), Internet service and mobile service provider, pages that you visit before and after using the Services, the date and time of your visit, download information, the links you click and areas you view within the Services, game metrics and usage data, and other standard server log information. We collect additional information when the Services crash or otherwise encounter a problem, including system and driver data. Consistent with your device permissions, we may collect or derive location information from your device’s GPS signal, Bluetooth connections, nearby WiFi networks, and similar device information. We also may derive location from your IP address.

Information we obtain from other sources. We may receive information about you from publicly and commercially available sources (as permitted by law), which we may combine with other information we receive from or about you. We also may receive information from third-party social networking services when you or other users choose to connect with those services.

II. HOW WE USE INFORMATION

We may use, record, systematize, store, update or modify, retrieve, delete, or otherwise process your information for the following purposes, using manual or automated means:

Our payment processors use payment information as necessary to complete transactions or as otherwise required by law.

We also may use the information we collect to:

• Provide the Services and deliver requested products and information, including technical support and responses to your questions or comments.

• Deliver emails, push notifications, text messages, alerts, and other communications about our Services and the products of our third-party partners, consistent with your choices.

• Customize and deliver the content and advertising you see when using the Services or third-party websites and services, consistent with your choices.

• Link the different devices that you might use to analyze your use of the Services, customize advertising, and otherwise provide and improve the Services.

• Analyze and address prohibited activities, including by assisting our efforts in policing users who may develop or use hacks or cheats to gain advantage over other users of the Services, and to otherwise enforce our Terms of Service and End User License Agreement.

• Analyze, develop, and improve the Services and new products and services, including by conducting and delivering surveys, polls, and research.

Nexon’s legal bases to process information for these purposes include that the processing is necessary for:

• Nexon’s legitimate interests, including those described above and as necessary to provide the Services.

• Compliance with Nexon’s legal obligations.

• The performance of the Terms of Service and End User License Agreement between Nexon and the user.

• Carrying out the obligations and exercising rights under applicable law.

• Where applicable, on the basis of the consent of users which may subsequently be withdrawn at any time by contacting us, without affecting the lawfulness of processing based on consent before its withdrawal. We rely on consent for certain advertising purposes, use of certain cookies, the collection of precise geolocation information, the combination of data across devices, and international transfers of personal information. For more information on how you can provide or withdraw your consent, see your choices.

III. WHEN INFORMATION IS SHARED

We limit when we share the information we collect to the following circumstances:

Within Nexon. We share information across the Nexon companies .

Business Partners. We share information with third-party partners and service providers, including payment processing and gateway companies, platform services, game developers, game publishers, customer support services, cloud storage and hosting providers, social media companies (who may collect information when you use the Services or when you connect the Services to your social media accounts) and analytics and advertising companies, to help us provide and improve the Services and operate our business. For more information about these business partners, please contact us.

Other Users. Your profile, including your username and the picture that you may provide, and information about your activities on the Services may be visible to other users of the Services or third-party sites and services. For example, your game results, scores, and profile information may be viewed by other users of the Services and, if you choose to link to social media sites like Facebook, viewed by users of such sites.

Legal Purposes. We may provide your information to third parties when we believe that doing so is required by law or to cooperate with regulators or law enforcement authorities. We may disclose your information in order to protect the rights or property of Nexon, including enforcing our Terms of Service and End User License Agreement, and others, or when we believe that there is an emergency that poses a threat to the health or safety of you, another person, or the public.

Corporate Transaction. If Nexon is involved in a corporate transaction, such as a merger, acquisition by another company, asset sale, or in the unlikely event of bankruptcy, we may transfer your information to the successor organization in such transaction in accordance with applicable law.

With Your Consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

IV. COOKIES AND SIMILAR TECHNOLOGIES

When you use the Services or interact with emails from us, we and our third-party business partners may collect and store information about your use of our Services using cookies, pixel tags, local storage, and similar technologies.

Cookies are small files that are automatically generated when you visit a website and are stored on your device. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your device. Local storage is similar to a cookie except that it can store larger amounts of information and can be stored elsewhere on your device.

We use cookies and similar technologies (collectively, “cookies”) for the following functions and purposes:

We allow third parties, including our analytics providers, advertising networks, and other advertising service providers, to collect information about your use of the Services across your applications and your different devices using cookies and similar technologies. These third parties may use this information to display advertisements on our Services and elsewhere online across different sites and services tailored to your interests, preferences, and characteristics. You can control the use and disclosure of the information for such purposes through Your Choices.

YOU CONSENT TO THE USE OF NON-ESSENTIAL COOKIES AND OTHER TECHNOLOGICAL MEANS AS IDENTIFIED IN THIS PRIVACY POLICY WITHOUT PREJUDICE TO ANY RIGHTS YOU MAY HAVE UNDER APPLICABLE LAW TO LATER REFUSE OUR USE.

V. YOUR CHOICES

Nexon provides you with a variety of choices to control the use and sharing of your information, including:

Email Communications. You may opt out of receiving commercial email messages from us by following the unsubscribe instructions provided in our emails. Please note that even if you have opted out of receiving commercial email messages, you may continue to receive messages related to your account, your transactions, and similar service-related messages.

Geolocation Information. Your device may enable you to control the collection of your precise geolocation information, and whether this information is shared with third parties, through the settings on your device. Please note that you may need to adjust multiple settings, and not just your location permissions, to opt out of providing precise location information. If you opt out of providing precise geolocation information, we may continue to derive your approximate location from your IP address and other information we may collect. For more information, please review your device settings.

Cookies and Similar Technologies. You may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable local storage and similar technologies. For example, Adobe Local Shared Objects can be controlled through the instructions on Adobe’s Setting Manager page . Deleting the cookies in your browser may in some cases cancel your choices for interest-based advertising. If you choose to refuse, disable, or delete cookies and similar technologies, some of the functionality of the Services may no longer be available to you.

Do Not Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Nexon currently does not take action in response to these signals.

Interest-Based Advertising. While it is not possible to turn off all advertising, you do have the ability to control whether you receive interest-based ads based on information collected or received about your online activities and interests over time and across unaffiliated sites and services and your different devices. You can opt out of receiving interest-based ads from companies that participate in self-regulatory programs such as the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), EDAA (EU), and DAAC (Canada) by following the instructions provided on their websites. If you are using a mobile app, you also may need to opt out of interest-based advertising on your mobile device or through the mobile application. For more information, check your device and mobile app settings. Please note that your opt-out choice will apply only to the browser and device you are using when you opt out.

Other Game and Device Permissions. You may be able to adjust your privacy settings for push notifications, address book sharing, and other information or features within the Services or your device permissions. Please review the settings for the Services and your device for more information. To stop the collection of information by a Nexon game, you can uninstall the game using the standard uninstall process available on your device or the app marketplace or network from which you installed the game.

Data Rights and Withdrawal of Consent

The laws in your country may provide you rights to request access to, correct, restrict, port, copy, or delete your information, request that we stop processing your information or delete your account, or withdraw or change the scope of your consent. If you withdraw your consent, we will stop processing your information for such purposes, but it will not affect the processing of information previously covered by your consent. Where technologically feasible and required by applicable law, we will port your information pursuant to your reasonable request. A request to withdraw consent, restrict or stop processing your information, or delete your account or information may result in your inability to access the Services or some of its features. To exercise your rights consistent with applicable law, please contact us.

VI. CHILDREN

We do not knowingly collect personal information from children who are under the age of 13 (or the age otherwise defined under applicable law) without parental consent or unless permitted by applicable law.

VII. HOW WE SECURE AND HOW LONG WE STORE INFORMATION

We maintain reasonable and appropriate physical, electronic, organizational, and procedural safeguards to protect your information. While we take reasonable precautions against possible loss, misuse, or unauthorized access, no storage system or transmission of data over the Internet can be guaranteed to be secure. Data we collect will be retained only for so long as reasonably necessary for the purposes set out above, unless applicable law requires otherwise.

VIII. INTERNATIONAL DATA TRANSFERS

Information we collect may be transferred to countries outside your home country for the purposes set out in this Privacy Policy. You understand that these countries, including Korea, Japan, and the United States, may not provide the same level of data privacy protection as the European Union/European Economic Area or your home country, and you hereby expressly consent to the transfer of your information to these countries for processing in accordance with this Privacy Policy. These transfers are essential to the provision of our Services and performance of the Terms of Service and End User License Agreement .

IX. CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy, in which case we will notify you before such changes take effect by posting the updated policy through the Services or otherwise in accordance with applicable law. Any changes to this Privacy Policy will take effect after a reasonable time period as specified in the notice of such changes.

X. CONTACT US

The privacy and security of your information is a top priority. If you have any questions or concerns about this Privacy Policy or our information practices, please contact the publisher for the particular Nexon Service, which is the data controller responsible for your information:

The laws in your country may permit you to lodge a complaint with the supervisory authority for data protection in your country if you believe that Nexon’s processing of your information infringes applicable law.