State Privacy Disclosures

Last Updated: 2024.10.16

These State Privacy Disclosures (“Disclosure”) supplement the Nexon Privacy Policy (“Privacy Policy”), and are effective as of the date above. Any capitalized terms used herein shall have the same meaning as under the Privacy Policy. Some states in the United States (such as California, Colorado, Connecticut, Florida, Montana, Nevada, Oregon, Texas, Utah, and Virginia) may provide additional rights with respect to the collection and use of your personal information. The rights available to you will depend on the laws in the state where you reside.

1.      Categories of Personal Information Collected or Disclosed for a Business Purpose

In the 12 months preceding the date of this Privacy Policy, we may have collected and/or disclosed for a business purpose the following categories of personal information:

·         Identifiers, including name, postal address, email address, and online identifiers such as IP address, profile picture, username, and nickname;

·         User records, including phone number, and payment information that payment processors collect when you make purchases (e.g., billing or mailing address, credit or debit card information);

·         Protected characteristics, such as gender;

·         Commercial information, including records of products or services purchased, obtained, or considered;

·         Internet and other electronic network activity information, including password, browsing history, search history, contacts from your device address book and social media accounts,  and interactions with a website, email, application, or advertisement;

·         Geolocation data;

·         Audio, electronic, visual or similar information, such as a profile picture for your account;

·         Inferences drawn from the above information reflecting your characteristics and preferences; and

·         Correspondence you send to us. 

Please note that we may collect and disclose other categories of personal information to the extent that you provide them through in-game chat, forums, or through our player support channels.  While some of the information that we collect may be considered sensitive personal information, we only process such information to provide our Services and within other exemptions under applicable law. For example, we may process your account login information to verify your identity.

2.      Purposes for Collecting Personal Information

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

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

3.      Data Retention

Data we collect will be retained only for so long as reasonably necessary for the purposes set out above and based on criteria such as the sensitivity of the data, whether we are legally required to retain the information, whether the information helps us protect other users and the integrity and security of our services, and what services and features you use.

4.      Sources of Personal Information

In addition to the information we receive from you, we also receive the categories of information described above from other sources including from other users of the Services, Internet service providers, data analytics providers, operating systems and platforms, publicly and commercially available sources (as permitted by law), marketing partners, game console providers and third-party social networking services, when you or other users choose to connect with those services.

5.      Disclosure of Personal Information

In the last 12 months, we have disclosed the personal information we collect in the following circumstances:

 

·         Within Nexon. We may disclose any of the categories of information that we collect across the Nexon companies.

·         Service Providers and Business Partners. We may disclose the following categories of information to our service providers and business partners: identifiers; user records; protected characteristics; commercial information; your contacts; internet or other electronic network activity information; geolocation data; audio, electronic, visual, or similar information; inferences; and correspondence you send to us. These service providers and business partners may include payment processing and gateway companies, platform services, game developers, game publishers, game console providers, customer support services providers, 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, for a variety of business purposes, including to help us provide and improve the Services and operate our business. For more information about these service providers and 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 any of the categories of information that we collect 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 any of the categories of information we collect to the successor organization in such transaction in accordance with applicable law.

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

If you access our Services through third-party devices or platforms, these third parties may be able to collect and process information about you, including information about your activity on the Services, and they may notify your connections on the third-party services, in accordance with their own privacy policies.

6.      Your Rights Regarding Your Personal Information

Depending on the state where you reside, you may have certain rights with respect to your personal information.  You may have the right to request that Nexon honor the following rights, where required by law:

 

·         Disclose what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, and information about the third parties to whom we disclose personal information (“Request to Know”);

·         Disclose the specific pieces of personal information we have collected about you (“Right to Access”);

·         Delete the personal information we have collected from you (“Request to Delete”);

·         Correct inaccurate personal information that we maintain about you (“Request to Correct”);

·         Opt out of the sharing of your personal information for purposes of cross-context behavioral advertising or targeted advertising (“Right to Opt-Out”);

·         Appeal our decision with respect to a request you have submitted to us (“Right to Appeal”). To exercise these rights, please contact us as described in Section 7 below.

We do not “sell” information for money or other valuable consideration, but we may have disclosed for cross-context behavioral advertising categories such as online identifiers, browsing history, and interactions to marketing and analytics partners.  You may opt out of the processing of personal information for cross-context behavioral advertising through the “Do Not Sell or Share My Personal Information” link on our website or by using a legally recognized opt-out preference signal, such as the Global Privacy Control (GPC).  Your request to opt-out will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us.

If you do not have an account or if you are not logged into your account, your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us.

We do not knowingly sell or share for cross-context behavioral advertising the information of consumers who are less than thirteen years of age without the consent of a parent or guardian or the information of consumers between the age of thirteen and sixteen without that user’s affirmative consent.

7.      How to Exercise Your Rights.

To exercise any of these rights, please email us as described in Section XI of our Privacy Policy [link] (Contact Us).  In the request, please specify which right you wish to exercise.

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. This may include personal information about you or information about your past purchases or use of our products or services, in order to help us verify your identity and process your request. Your request may be denied if we are unable to verify your identity. If you have an account with us through the Services that is password-protected, we may verify your identity through our existing authentication practices for your account.

8.      Authorized Agent.

You may be entitled, in accordance with applicable law, to submit a request through an authorized agent.  To designate an authorized agent to exercise your rights and choices on your behalf, please provide written proof of your agent’s permission to do so. A request from an agent may be denied if such agent does not submit proof that the agent was authorized by the user to act on the user’s behalf, and/or the agent’s identity could not be verified.

9.      No Discrimination.

Nexon will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on our Services may change or no longer be available.