PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE

Last Updated: January 30, 2026

Thank you for using Proxima Beta’s (as defined below) products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy. This summary is to help you navigate the privacy policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we need to provide the Game Services?

If you register an account to use the Game then we will need some information from you to set this up. We will also process some information when you use the Game (e.g., to make sure your progress is saved) and when you buy items (e.g., to ensure you get the purchased content). If you choose to set up your Game profile using a social media account, we also collect information from that social media account. If you choose, you can provide certain other information to personalise the gaming experience and enable Game features, or participate in Game Services. If you choose to use the eSports Website, we will need your Game login credentials and other information, such as your email address, user and account information, and information to enable you to form or join teams and participate in eSport competitions for the Game. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns. More Information.

How will we use your information?

We use your information to provide the many functions and services that comprise the Game Services. We also use your information for account verification, security purposes, to support and improve the Game Services, to process transactions as part of the Game Services, to provide you with game updates, and to enforce our terms, conditions and policies. We do not disclose your information to any third parties, except where we need to in order to provide the Game Services (e.g., use local cloud providers or to back up your data; using our affiliates around the world to help us to deliver the Game Services) or monitor the success of our marketing and advertising programs, or where we are instructed to by a court, authority or compelled by law. More Information.

Who do we disclose your information to?

We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data, support ticketing and fraud detection). When we use a third party, we only do this to process or store your information for the purposes described in this privacy policy. We also have affiliates around the world who help us deliver the Game Services and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.

Where do we process your information?

Our servers are located in Singapore, Dubai, Brazil, United States, Germany (in respect of certain data only) and Russia (in the case of users located in Russia only). Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore, the People’s Republic of China, Egypt, Turkiye, Malaysia, Brazil and Mexico. More Information.

How long do we keep hold of your information?

We generally retain your information for the period during which you maintain an account for this Game after which time your data is deleted (as further described in this privacy policy), unless otherwise required by applicable laws. More Information.

How can I exercise my rights over my information?

Depending on where you live, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.

How to get in touch with us

If you have any questions about anything in this policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will update the policy here. More Information.

Contact Information

Data Controller: Proxima Beta Pte. Limited | Online Form at here

EU Representative: Proxima Beta Europe B.V. | Online Form at here

UK Representative: Image Frame Investment (UK) Limited | Online Form at here

Serbia Representative: Karanovic & Partners o.a.d. Beograd. | Email: local.representative@karanovicpartners.com

Thailand Representative: Tencent (Thailand) Company Limited | Online Form at here

Türkiye Data Controller Representative: Özdağıstanli Ekici Avukatlık Ortaklığı. | Email: turkeydatarep_proximabeta@iptech-legal.com (Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorized for any other matters such as in-Game conduct, suspensions, investigations, civil or criminal complaints.)

Welcome to PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE!

This privacy policy explains the when, how and why when it comes to the processing of your personal information in connection with the mobile game PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE (“PUBGM” or the “Game”), its website (“Website”), its eSports Website (“eSports Website”), and its related interactive activities and events (“Events”) (the Game, the Website, the eSports Website, and the Events, together comprise the “Game Services” and the Website and the eSports Website together comprise the “Websites”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this privacy policy describes, please do not provide your information when requested and stop using the Game Services. By using the Game Services, you are accepting our rules regarding your personal information as described in this privacy policy.

This Game has been developed by Proxima Beta Pte. Limited (“we”, “us”, “our”, or “Proxima Beta”).

For the purpose of data protection laws, the data controller of your personal information in relation to the Game Services is Proxima Beta Pte. Limited. The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore.

Our data protection officer can be contacted using our Online form here.

Our representatives for data protection purposes in certain jurisdictions are as follows:

EU	Proxima Beta Europe B.V.	Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands	Online Form at here
UK	Image Frame Investment (UK) Limited	4th Floor 80 Strand London WC2R 0RL	Online Form at here
Serbia	Karanovic & Partners o.a.d. Beograd	Resavska 23, Belgrade, 11000, Serbia	local.representative@karanovicpartners.com
Thailand	Tencent (Thailand) Company Limited	8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand	Online Form at here
Türkiye	Özdağıstanli Ekici Avukatlık Ortaklığı.	Nidakule Ataşehir Kuzey Begonya Sok. No:3 Kat. 17 D: 162 34746 Ataşehir / İstanbul, Türkiye Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-Game conduct, suspensions, investigations, civil or criminal complaints.	turkeydatarep_proximabeta@iptech-legal.com

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime using our Online form here.

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How We Use Your Personal Information” below.

We process information in the following ways:

· when you directly provide it to us;

· when you interact with us;

· when you use our Game Services; and

· when we receive information from third parties.

The following is a summary and provides relevant examples of the types of personal information we process:

A. Information you directly provide to us

ⓘ We will process personal information that you directly provide to us, such as:

· If you create an account with us, we will process basic registration information that you provide such as your nickname, the country you live in, your email address, mobile phone number, etc.

· We will also process information you voluntarily provide, such as when you use our social features to send a message or share a photo or sign up for/or attend an event.

Examples of information you directly provide to us include:

· When you create and manage an account, we will process the registration and account information you provide such as your nickname, date of birth (we do not store the full date of birth but keep records such as your month and year of birth to make sure the Game Service is age appropriate), region location manually selected by you, email address, mobile phone number, password and similar. In some cases, you can also elect to provide additional information such as your gender.

· When you bind your account with your mobile phone number and/or email address, we will process the information you provide.

· If you choose to log in via your social media account or unified game account (e.g. WeChat, QQ, Facebook, VKontakte, Twitter, Google Play, Apple Game Centre, LINE, WhatsApp, Level Infinite Pass, as applicable), we will process your user ID, nickname, gender, profile picture. We will also import the social media user ID, nickname and profile picture of your friends from your social media profile so that you can connect with your friends and share game activities with your friends.

· If you make a purchase or transact on our platform or Service, we will process payment and billing information such as your credit card number, expiry date, CVC, first name and family name, email address, billing address and similar.

· If you use social features within our Game Services, such as finding your friends that use the same Service and sending, uploading or publishing text, audio, visual and/or other electronic communications information to us, to another user or to a wider group or forum, we will process the information you provide.

· If you respond to our surveys and other enquiries in relation to our Game Services, we will process your feedback (in particular, your user ID, age, gender, contact information, other responses you choose to provide and similar).

· If you interact with us, such as seeking customer support (either through chatting with our staff or interacting with an AI-powered chatbot) or submitting a data request, we will process the information you provide such as user ID, email, any evidence you submit for investigation and similar.

· If you sign up for our communications or email alerts, for example, about our Game Services updates and exciting upcoming games, events or activities, we will process the information you voluntarily provide to us.

· If you sign up and participate in events we organise (such as e-sports events or community events), we will process the information you provide such as your user ID, your team's name, team's logo, date of birth, country, contact information, name on your passport, postal/zip code and address and similar. Depending on the nature of the event, we may also require additional information, such as to verify your identity, confirm your eligibility to attend the event, assist with travel arrangements, and distribute prizes.

· If you engage with certain functions of our Game Services, for example, sending text, audio or images to our AI-driven functions for creative output or granting us access to specific content such as a selected photo album on your device, we will process the information you provide.

B. Information we process when you interact with us

ⓘ Information we process when you interact with us (e.g. when you play games or participate in relevant activities and events) includes:

· We will generally process information about your in-game profile, your gameplay data and your other interactions with us and other players.

· If you sign up to participate in certain tournaments or events, we may take photos, video record and/or livestream these tournaments or events, in which case certain data relating to you or your team (such as your game performance) will be processed, captured and displayed on public platforms for a broader audience to enjoy. We may also process information in relation to your participation, submitted content, records or earnings.

Information we process includes:

· Player's identity, role and appearance: information such user ID, role name, role ID, skin, gender, photo, IP address and similar.

· Gameplay data: information such as your in-game actions (e.g., movement, hit and kill), weapons, level, scores, in-game currency, gameplay performance, start and end times, task completion records, achievements and other relevant behaviour and performance information about your interaction with the game.

· Team and social: information such as your performance with friends and other players, rankings, leaderboards and similar.

· Gameplay time: for users in certain regions, we will process gameplay time data such as your daily cumulative gameplay time and your daily rest time to prevent gaming addiction.

· Photos, video clips and livestreams: in some cases, such as when you enable our replay function (if applicable) or when we capture in-game video clips for anti-cheating and security review, we will collect and process information such game photos, screenshots, video clips and similar. If you choose to participate in the events and tournaments, we may also take photos, video and/or livestream these events and tournaments.

C. Other information we automatically process when you use our Game Services

ⓘ We also process some information automatically when you use our Game Services, such as:

· Your usage information reflecting how you interact with us.

· Information about your device and hardware.

· Your transaction record.

· Approximate and precise geolocation data (if applicable).

· Data that allows us to prevent cheating and verify compliance with our terms with you.

Information we automatically process when you use our Game Services includes:

· Usage information and statistics about how you interact with our Game Services, such as your website/application usage, saved preferences, crash reports, the URLs of websites that you have visited, time spent on a page, last active time, session count, your clicks on certain pages, your interaction with ads such as any ads you click and the type of ad you view and similar.

· Technical information about your device, hardware, software and network, such as your hardware identifiers, hardware-related information, device brand and manufacturer, screen resolution, recharge and consumption record, WiFi-related data such as strength and speed and other network information.

· Browser information, such as your browser type, browser version, language preference and similar.

· Limited approximate geolocation data such as the one that is derived from your IP address, internet connection or device (if applicable) in Game Services with enabled features including finding your friends or locating players near you, etc.; or location information you provide (such as city or province) for region-specific features like leaderboards or regional chats, etc.

· Precise geolocation data information such the one that is derived from your GPS in Game Services with enabled features, including finding your friends or matches, etc.

· Transaction records such as purchase history, details of transaction (such as transaction time, items purchased, cost and currency) and similar.

· Anti-cheating and security-related information including your hardware information, data relating to the presence of restricted files and emulators or restricted modifications to files and other data revealed by anti-cheat testing.

· Information used for checking your compliance with terms you agreed with us, including the end-user licence agreement (EULA) and other similar agreements.

ⓘ Cookies and other technologies

We use a variety of technologies such as cookies, software development kits (SDKs), log files and analytics tools to automatically process types of information listed above. If the Game Services that you use have cookies:

· You can control the use of cookies at the individual browser level.

· If you reject some or all cookies, you will usually still be able to use our websites and Game Services, but your ability to use or enjoy features or areas of our websites may be limited or deactivated.

For further information, click here.

D. Information we receive from third parties

ⓘ In some cases, we will process information about you received from third parties, including:

· Information we receive from third parties in connection with your use of our Game Services, for example, when you login through your account with a social media or third-party platform (such as WeChat, VKontakte, Meta, X, Google Play, Line, Apple, Whatsapp etc.), we will process information such as your user ID, nickname, profile picture, user token and email address associated with that account.

· Information we receive when other players share their friend/contact list from a third-party platform with us.

· Selected partners who are permitted to share additional information or insights about or similar to you (specifically, to help our understanding what you are enjoying about our Game Services or advertisements you may enjoy). If you interact with an advertisement on an external website, the company that operates that website may share some information with us in accordance with its own privacy practices.

Children

For those Game Services that are available to children, users who are under the age set out in the table below should not access our Game Services for any purposes unless your parent or guardian has agreed to this by providing their consent (if this option is available in your location). If you are located in a region not listed below, or if you are unsure, you should not access our Game Services for any purposes and you should seek guidance from your parent or guardian.

Region in which the user is located	Minimum age of the user
Algeria	19
Argentina	13
Australia	18
Bangladesh	18
Brazil	18
Cambodia	18
Canada	13
Colombia	18
Egypt	18
European Economic Area	16 (subject to deviations by EU member states)
Hong Kong	18
Indonesia	21
Kazakhstan	18
Kingdom of Saudi Arabia	18
Kuwait	21
Macau	18
Malaysia	18
Mexico	18
Morocco	18
Myanmar	18
New Zealand	16
Nigeria	13
Philippines	18
Qatar	18
Russia	14
Serbia	15
Singapore	13
South Africa	18
Switzerland	14
Sri Lanka	18
Thailand	20
Tunisia	18
Türkiye	18
United Arab Emirates	21
United Kingdom	16
United States	13

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental or guardian consent, or if you are the parent or guardian of the user and wish to withdraw the consent, please submit your request at here and we will delete such information.

2. How We Use Your Personal Information

We use your information to help us provide, improve, customise, analyse and promote our Game Services, including:

· providing the experiences, products and services you request and engage with, such as enabling and facilitating your ability to join and take part in games and events and fulfilling orders you request.

· providing customer support, such as addressing a complaint and handling a data request.

· operating, developing and improving our Game Services and enhancing user experience.

· managing alpha, beta, early access and patch tests and collecting feedback from players who seek to participate in tests.

· personalising your experience, including presenting content or features better tailored to your interests and leveraging AI tools to generate content (e.g. personalised gaming content).

· identifying, fixing and troubleshooting bugs or functionality errors.

· assessing and improving the quality and features of our Game Services and products, such as using your device and network information to analyse gaming performance quality on different device models and networks to optimise your experience.

· undertaking data analysis and research to better understand our players and market and programs and further develop and update our Game Services.

· securing our Game Services by detecting security incidents and protecting against cheating, malicious, deceptive, fraudulent or illegal actions.

· communicating our new products, services, enhancement, offers, promotions or other information to you.

· marketing and showcasing our Game Services, such as promoting our Game Services in our platform as well as third-party platforms, managing and measuring the effectiveness of our advertisements and sending you information about our products, services and events tailored to your interests.

· performing or providing information in connection with audits, transactions and other compliance activities as well as complying with our legal or contractual obligations.

· other purposes that are otherwise disclosed to you on or prior to processing your personal information.

We also handle information that does not personally identify you, such as aggregated or de-identified data that we generate. This data helps us gain insights into larger user groups. Our privacy policy does not limit our ability to process data that does not personally identify you, and we may use and share aggregated or de-identified data for any legally permissible purpose.

Legal basis of processing

The legal bases we rely on to process your personal information vary and depend on multiple factors, including: (i) the Game Services you use; (ii) the type of personal information involved; (iii) the context within which we process your information; and (iv) your country of residence.

The following table provides you an overview of legal bases we rely on, the corresponding purposes for processing, and the types of processed information.

If the legal bases below are not applicable in your jurisdiction, by using the Game Service you consent to the collection, use, disclosure, transfer, processing, export (to the extent permitted by applicable laws) and storage of your personal information as described in this privacy policy.

Basis	Why	Examples of data categories
Contract	It is necessary to perform our contract with you to: · provide the experiences, products and services you request and engage with, such as enabling and facilitating your ability to join and take part in games and events (including using the social and AI features therein) and fulfilling orders you request. · provide you with customer support.	· Registration and account information (e.g., nickname, date of birth (though full date of birth is not stored), age, email address, mobile phone number and other registration info when you set up your profile and sign up for activities and tournaments) · Account linking (e.g. if you log in using Meta or other social media account, we import information such as user ID, nickname, profile picture, email address, friend list associated with that account) · Gameplay data and device information · Information we process when you use certain features within our Game Services (if available, e.g., text, audio, visual and other interaction communications) · Information about your region (e.g., city selected by you at registration, or region information derived from your IP address) · Payment and billing information and transaction record · Information we process to provide you customer service (e.g., user ID, email, any evidence you submit for investigation, verification information)
Legitimate Interests	For our legitimate interests or those of a third party (such as a transaction counterparty or lender) to: · provide you with customer support.	· Information we process to provide you customer service (e.g., user ID, email, any evidence you submit for investigation, verification information)
	· identify, fix and troubleshoot bugs or functionality errors.	· Information we process for data analytics to fix bugs and monitor quality (e.g., device and network information)
	· undertake data analysis and research to better understand our players and market and programs, personalise your experience and further develop our Game Services.	· Gameplay information (e.g. in-game actions and behaviours, in-game currency, gameplay time) · Transaction record (e.g. purchase history) · Usage information and statistics about how you interact with our Game Services · Technical and device information
	· assess and improve the quality and features of our Game Services and products, such as analyse gaming performance quality on different device models and networks to optimise your experience.	· Technical information about your device, hardware, software and network (e.g., hardware-related information, device brand and manufacturer, WiFi-related data) · De‑identified interaction data with AI to operate and improve AI‑based features (if available)
	· secure our Game Services by detecting and preventing security incidents and protecting against cheating, malicious and deceptive actions and to maintain a fair environment for our games and Game Services.	· Anti-cheating and security-related information (e.g., hardware information, cheat tool detection information (e.g. device data and click events), data relating to the presence of restricted files and emulators, reported chat messages or screenshots, player reports, data of players suspected of cheating, malicious content information (e.g. nicknames, profile photos, chat histories, audio self-introductions)) , transaction record
	· monitor compliance with our terms.	· Information used for checking your compliance with terms you agreed with us (e.g., the end-user licence agreement (EULA))
	· engage in commercial transactions (for example, if a third party acquires our business).	· Registration and account information
	· manage and measure the effectiveness of our advertisements.	· Advertising engagement and interaction information (e.g., information about your interaction with ads)
	· to the extent permissible and applicable in your region, send you information on game promotions and activities.	· Promotion activities (e.g., telephone number, email address)
	· to support our promotional activities on social and traditional media.	· Media data (pictures, videos or similar media data)
Legal Obligations	It is necessary to fulfil an applicable legal or regulatory obligation to which we are subject, in order to: · comply with applicable laws and requests from regulatory, governmental, tax and law enforcement authorities, and data subjects; · carry out audit checks; and · prevent and detect fraud.	· Information we process to identify abuse, harassment or illegal actions (e.g., user ID, nickname, profile picture, reported chat messages or screenshots) · Information we provide in response to requests from law enforcement or other government authorities, and data subject requests · Information used for assessing and ensuring compliance (e.g. date of birth and region location; user-generated information)
Legal Obligations	· meet the legal obligations we have to you, such as handling a data access request.	· Information we process when you initiate a data subject request (e.g., user ID, email address)
Consent	We also process your information based on your consent (where such consent is required by law) to: · send you email or in-game notifications about our new promotions, products and activities.	· Email address and user ID, or other social media or messaging platform information
	· participate in our surveys or tests.	· Information we process when you respond to our surveys and other enquiries (e.g., user ID, age, gender, nickname, location, contact information)
	· participate in our events and activities that may capture and showcase your performance.	· Information we process when you participate in tournaments or events (e.g., user ID, gameplay data, game photos, screenshots, video clips)
	· activate certain features or offerings.	· Information we process when you choose to activate certain feature or offering (as applicable, e.g., user ID, registration and account information, your preferences, gameplay data, text, audio, visual communications that you upload to or generate as part of the feature or offering, technical data)

3. How We Store and Disclose Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide you with the Game Services, your personal information will be processed on servers that may not be located where you live. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore, the People’s Republic of China, Egypt, Turkiye, Malaysia, Brazil and Mexico. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers for the Game Services are located in:

· Singapore,

· Dubai, Brazil, United States, Germany (in respect of certain data only);

· Russia (in the case of users located in Russia only);

For completeness, we may also have servers located in other jurisdictions which process or store data for the Game Services that is not personal information, such as servers in the United States for storage of certain game data that does not contain your personal information.

If you choose to provide us with your telephone number and/or email to receive information on game updates via SMS and/or email and in order for us to send you SMS verification codes, your information will be stored in Singapore. Additionally, the SMS service providers located in Hong Kong SAR, Singapore as well as your local carrier will have access to the data, including to the SMS Sending Records.

Only where necessary will we disclose your personal information to third parties. Situations where this occur are:

· Third parties that provide services in support of the Game Services, including providers of cloud and network services that process or back up information identified in this privacy policy on their servers for the purpose of providing the Game Services; Google Cloud Platform, a provider of cloud services that stores email subscription data, email segmentation data and email engagement performance data in Germany; Amazon Web Services, a provider of cloud email services who processes email subscription data and email events in Singapore and the United States and other providers for the purpose of sharing of in-game photos on WeChat, Facebook, VKontakte, QQ, Twitter, Google Play, Game Center or LINE (as applicable), for the purpose of providing customer support and services (including the Supercore Players-only customer service), for the purpose of user authentication, for the purpose of processing customer support ticket IDs and support communication or Q&As, for the purpose of analysing crashes and improving service performance, for the purpose of providing marketing and advertisements and monitoring the success of our marketing and advertising programs, for the purpose of providing you with updates and information regarding the Game Services, for the purpose of providing translations, for the purpose of detecting whether user-generated content and chats violate applicable laws, our terms or community rules, for the purpose of organizing and promoting tournaments and e-sports events, for the purpose of distributing digital prizes, for the purpose of delivering physical prizes, for the purpose of facilitating your participation in Game competitions or eSports events on third-party services, for the purpose of payment processing services (including security and fraud detection), for the purpose of informing and improving the refund process if you request a refund, and for the purpose of data analytics and providing push notifications. Certain personal information processed for data analytics and push notification purposes may also be stored and processed by our third party Firebase’s server in the United States. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services in support of the Game Services.

Companies within our corporate group who process your personal information in order to operate the Game Services. All related group companies may only use your personal information in accordance with this privacy policy.

Regulators and judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, enforce our terms, conditions and policies, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

4. The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Game Services or otherwise via the Internet; any transmission is at your own risk.

5. Data Retention

Personal Information	Retention Policy
Game
Nickname, Hashed Nickname, User ID, IP Address Analytics data CrashSight data Comment and Personal Center Data Co-Creation Wallet Information WOW AI Assistant information	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Social Connect Information: WeChat · QQ	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days or as otherwise required by law.
Social Connect Information: · VKontakte · Twitter · Facebook · Google Play · Game Center · LINE · Apple · WhatsApp	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Gender	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Gender Information	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Date of Birth	Not stored. This is processed device-side only and is not transferred to us.
Email address (for verification of parental or guardian consent) Region Location (manually selected by you) Game Play Statistics (Level, Heroes, Score/s), date and time stamps of actions	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Location information Birthday feature information	The GPS information will be immediately deleted after being converted into country and city information. Other data will be stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 90 days after the Game is shut down, before it is deleted.
Battle Information	Not stored. This is processed during the battle only.
Game-based Event Information (digital prizes)	Stored for 1 year after the conclusion of the Event.
Game-based Event Information (physical prizes)	Stored for 1 year after the conclusion of the Event.
Game-based Event Information (cash prizes)	Stored for 6 months after the conclusion of the Event.
Calling Card Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Data Subject Request Information	Stored for 3 years.
Gameplay Management System Information	Cached for the day and deleted every 24 hours
Chat Communications (Audio message) – whether inside a battle (e.g. during actual gameplay) or outside a battle (e.g. in game lobby)	We do not store this information.
Chat Communications (Text) – outside and inside a battle	Stored for 7 days on our servers and deleted automatically upon expiry of such period.
Device ID, Device Information, registration time and login time	Device ID, Device Information (except VPN status), registration time and login time: Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days (or within 7 days of user request for account or data deletion in respect of XID). Where you do not request for account deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted. VPN status: Not stored. This is processed device-side only and is not transferred to us.
Routing Information	Stored for 1 year.
WiFi SSID	Not stored. This is processed device-side only and is not transferred to us.
Friends List (WeChat, Facebook, QQ, VKontakte, Twitter)	Stored for the duration of each session on the Game and deleted within 1 hour after you log out.
Friends List (manually added by you)	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Advertising ID and select device information (User ID, Device ID, IP address and engagement data and search terms) World of Wonder Advertising-related information	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for up to 1 year after the Game is shut down, before it is deleted.
Transaction Records (in-app) Transaction Records (third party other than Google Play or iOS App Store)	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for the duration of any retention periods for which such data must be retained in order to comply with our legal obligations.
Transaction Identifiers Refund Information	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Customer Support Ticket ID & User Communications with Support or Q&A function	Support data is deleted within 30 days of a lawful request from you for the erasure of such data (see the Erasure section of this privacy policy).
Customer Service Data Supercore Player Analytics Data (except chat history with the Supercore Players-only customer service team)	Stored for 90 days. Upon a deletion request, we will delete the data within 30 days.
Supercore Player Outreach Information Supercore Player Qualification Information	Stored for the lifetime of the Game and then deleted within 30 days. If you request for deletion, data will be deleted within 7 days after your request.
Security and Operation Information	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Security-Related Information (if you are using the Game on a PC)	We generally retain this data for no longer than 90 days with the exceptions listed below. · File sample collection and memory sample collection related to confirmed malicious activities: up to 10 years; · In-game process information and system information: up to 10 years; · Security authentication: up to 5 years. Upon a deletion request, we will delete the data within 30 days except where they relate to confirmed malicious activities.
Illegal profile photos	If no violation is found, stored for 1 day. If any violation is found, stored for the shorter of 3 years or until account deletion in accordance with your request and then deleted within 30 days.
Reported chat data	For End User License Agreement violations: user ID and documented chat are stored for 180 days if any violation is found. For improving tools used to identify violations: Documented chat (which is anonymized) is stored for the lifetime of your use of the Game (i.e. until account or data deletion in accordance with your request) and then deleted within 30 days. Where you do not request for deletion, such data is retained for 3 months after the Game is shut down, before it is deleted. In the case of audio chat: Real-time voice chat data will only be stored on your device and not be stored on our servers, unless a report or complaint is made, in which case the last 30 seconds of the data are stored on our servers to enable us to review the complaint or report. This data will be deleted as soon as the review is complete and in any event within 30 days. For improving tools used to identify violations for voice chat data and to facilitates the review of penalties for violations and misjudgments: If any violation is found, the voice file (which is marked, anonymized and encrypted) is stored for 1 year.
In-Game screenshots for player reports from Game-based Events	If you choose not to upload the screenshot, not stored by us. If you upload the screenshot and no violation is found, stored for 90 days. If you upload the screenshot and no violation is found, stored until the Game is shut down unless you request to delete your Game account or data, upon which such data will be deleted within 30 days.
Video clips of suspected cheating behaviour	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Complaint Verification Information	If no violation is found, stored for 90 days. Upon a deletion request, we delete the data within 15 business days. If any violation is found, stored for the lifetime of your use of the Game (i.e. until account or data deletion in accordance with your request) and then deleted within 15 business days. Where you do not request for deletion, such data is retained for 30 days after the Game is shut down, before it is deleted.
Malicious Content Information	Free text is only processed momentarily and not stored. Other information is stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Cheat tool detection information	For device name of any external devices connected to your mobile phone: stored for up to 7 days. For other information: If no violation is found, stored for up to 7 days. If any violation is found, stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request and then deleted within 30 days). In some cases, such data may be stored for a shorter period (e.g., 3 years after collection).
Cheat Behaviour Detection Information	Where you do not request for account or data deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted. Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Real-Time Game Review Information	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Anti-Plug-in Information	Not stored if not reported or suspected of cheating. If reported or if cheating is suspected: Replay video is stored for 120 days. Other information is stored for 30 days.
Game Player Suspension Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Survey Information	Stored for up to 1 year.
In-Game screenshot information	In-game screenshot: Not stored. This is processed device-side only and is not transferred to us. Screenshot log data: Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days.
Highlights Replay Information	For any highlights replay video you share: Highlights Replay Information is stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 90 days after the Game is shut down, before it is deleted. For videos not shared: Not stored. Please note that any highlights published outside of the Game (for example, to social media), may remain available via such services even if deleted from the Game.
Leaderboard Highlights Information	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Beta Test Account Authentication Information	Stored for the lifetime of your use of the Beta test (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 2 months, before it is deleted.
Group Photo Event Information	For any photo you share: The photo you upload and the photo generated are processed device-side only and are not transferred to us. Your user ID and election to share the photo generated are stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days. For photos not shared: No information is stored. This is processed device-side only and is not transferred to us.
Sweepstakes Participation Information	Stored for up to 1 year after the conclusion of the sweepstakes event.
Club Information (general) Club Information (country and region, province, city, language, friends list) Club Information (UGC maps)	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any picture, text, audio and video content, comments and other posts you share any time.
World of Wonder Creations Interaction Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
World of Wonder (WOW) Incentive Program Information	Stored for 2 years, unless you request to delete your Game account or data, upon which such data will be deleted within 30 days.
UGC Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any picture, text, audio and video content you share any time. In relation to text or picture content sent by users in-Game: If no violation is found, stored for 60 days.
Moments Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any video content you share any time.
Clan Announcement Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any announcement you post any time.
Club Feature Performance Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Tournament Qualification Information	Stored for up to 6 months from the time of collection.
Tournament Invitation Information (free entry)	Stored for up to 6 months from the time of collection.
Tournament Registration Information	Stored for 3 months from the time of collection.
E-sports Event Registration Information	Stored for up to 3 months from the conclusion of the tournament.
Tournament Recording Information	Where this is used to validate Game user and to investigate any allegation of cheating, stored for up to 6 months from the conclusion of the tournament. Where this is used in marketing and promotional materials, stored for the duration of the marketing campaign.
Tournament Livestream Information	We may enable the livestream videos to remain available on the platform that broadcasts the livestream in perpetuity. We may also separately retain the video recordings of the livestreams in perpetuity.
Tournament or Event Prize Delivery Information	Stored for up to 6 months from the conclusion of the tournament.
Event Photos and Videos	We may post event photos and videos to our platforms our third party social media platforms in perpetuity. We may also separately retain the photos and videos in perpetuity.
Email Segmentation Data	Stored for the lifetime of your use of the Service and deleted within 7 business days if you request for deletion, unless otherwise required to ensure compliance with terms, conditions, policies and legal obligations.
Email Engagement Performance Data	Stored for 6 months and deleted within 7 business days if you request for deletion, unless otherwise required to ensure compliance with terms, conditions, policies and legal obligations.
Tournament Player Suspension Information	Stored for the duration of the suspension.
Tournament Suspension Notice Information	Stored for the duration of the suspension
FACEIT Information	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days or as otherwise required by law. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Sharing Event Report Information	Stored for 1 year after the conclusion of the event.
Season and Anniversary Review Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Battle Performance Information (other than number of kills)	Deleted when the battle is over.
Battle Performance Information (number of kills)	Stored for 21 days.
Battle Matchmaking Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Telephone number or email for the purposes of binding your account with your telephone number and/or email address and/or associated social media account, for providing game updates and offers, for providing game promotion emails where applicable to your region, for providing manual customer service, and for ensuring compliance Two-factor authentication information SMS Sending Records	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted. SMS Sending Records will be stored by the SMS service provider for up to three months after which they will be deleted automatically.
Telephone number and User ID (if you elect to be featured on leaderboards) SMS Sending Records	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted. SMS Sending Records will be stored by the SMS service provider for up to three months after which they will be deleted automatically.
Offline Team Invitation Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Account Security Alert Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Captcha Data Chat history with the Supercore Players-only customer service team	Stored for 30 days from the date of collection and then deleted.
UGC Map Information UGC Map Review Information UGC Map Creator Certification Information	Map scene recording: Stored for 14 days. Other information: Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. We may also host events whereby map creators may submit their, and other users can vote on, UGC maps. For such events, we also store UGC Map Information for 6 months. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Friend Interaction Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Friend Interaction Push Notification Information	Stored for up to 3 months.
PDP Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within one month. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
PDP Moderation Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within one month. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Photo Wall Information	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. You can also at any time delete any photo you share. Stored for 30 days for content moderation.
Home Smart Butler information	Chat history and chat summary will be stored for 7 days. Other data will be stored for the lifetime of your use of the Game unless you request to delete your Game account or data, upon which such data will be deleted within 30 days.
AI Teammate Information	Stored for 6 months, unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Voice data will be deleted within 30 days.
Advertising Information (Firebase)	Stored for 14 months.
Advertising Information (Meta)	Stored for 9 days.
eSports Website
Social Connect Information Email Login Information User Registration Information Account Binding Information Notification Information eSports Website Event Registration Information Customer Support Ticket ID & User Communications with Support	Stored for the lifetime of your use of the Game Services unless you request to delete your Game account or data, upon which such data will be deleted within 30 days. Where you do not request for account or data deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted. If you participate in eSports events hosted on third party platforms or services, please also refer to the relevant third party’s privacy policy and retention policy.
Team Information	Stored until 30 days from dissolution of team.
Chat Data	We do not store this on our servers. This is only processed momentarily by us to deliver your chat communications.
In relation to Events
Identifying Information	Stored for one year after the end of the Event, or deleted within 30 days from the receipt of your deletion request. In case those information are necessary to maintain the record of the participation to the Event, such will be kept until Game Service is shut down.
Device and Network Information Gameplay and Interaction Data	Stored for one year after your last interaction with the Event, or deleted within 30 days from the receipt of your deletion request. In case those information are necessary to maintain the record of the participation to the Event, such will be kept until Game Service is shut down.
Financial Information	Stored for seven years after the completion of the transaction, or deleted within 30 days from the receipt of your deletion request.
Media and Additional Data	Stored until the Game Service is shut down, or deleted within 30 days from the receipt of your deletion request.
Survey Information	Stored for up to 1 year.
Website Events
Social Connect Information Email Login Information Lucky Draw Winner Information	Stored until 30 days after the conclusion of the event.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

6. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Game Services, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in the Relevant Jurisdictions. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada, India, Russia and the Kingdom of Saudi Arabia.

The sub-sections entitled “Email Opt-Out” and “SMS Opt-Out” also apply to users that are located in Canada, Egypt, India, Malaysia, Mexico, Russia, Singapore, the United Arab Emirates and the United States.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please submit your request at here.

Access

You have the right to access personal information we hold about you, inquire how we use it, and who we disclose it to by contacting us at here. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at here.

Portability

You have the right to receive a copy of certain personal information we process about you by contacting us at here. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. You have the right to receive this personal information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer it to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can correct the personal information we hold about you by logging into your account and/or by contacting us at here. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at here.

Erasure

You can delete your account, or remove certain personal information, by logging into your account and/or by contacting us at here. If there is any other personal information you believe we process that you would like us to erase, please contact us at here.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game Services and there are grounds for erasure, we will use reasonable steps to try to tell others who are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at here.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at here. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

Email Opt-out

You may choose to stop receiving game update emails or, where applicable to your region, game promotion emails, from us by following the unsubscribe instructions included in these emails or you can contact us at service@pubgmobile.com.

SMS Opt-out

You may opt out of receiving game update marketing or advertising text messages by contacting us at service@pubgmobile.com, and sharing the phone number that you would like to opt out. For text messages, you also may be able to text “STOP” in response to a text message that you receive.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Game Services for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Advertising

We will only send marketing messages to you if we have your consent. You may choose to stop receiving marketing messages from us by using the unsubscribe option in the message or contacting us at here.

7. Contact & Complaints

You can reach us using our Online form here to submit Data Subject Rights requests and any questions or concerns related to data privacy. This Online Form also allows you to contact our Data Protection Officer regarding your privacy-related inquiries.

If you are an agent or official of a regulatory authority and have a specific data and privacy regulatory inquiry, please use our Data and Privacy Regulatory Inquiry Form here

We will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the region in which you live or work where you consider we have infringed data protection laws.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

8. Changes

If we make any material changes to this privacy policy, we will post the updated policy here and notify you in accordance with relevant legal requirements.

9. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.

SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS

Some jurisdictions’ laws contain additional terms for users of the Game Services, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our privacy policy above.

Algeria

By using the Game Services, you give us your consent for the collection, storage, treatment and use of your personal information, and transfer of your personal information to a third party (such as local cloud providers to back up your data or our affiliates around the world to help us deliver the Game Services) located in Singapore (as described in the Privacy Policy) where it is manually and electronically treated.

Argentina

Your rights

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar).

Data transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing us your personal information and by using the Game Services, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Australia

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us using the details provided here.

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us using the details provided here.

Children

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game Services.

Transacting Anonymously

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Game Services. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Game Services, including social media integration and in-Game purchases.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Bangladesh

Agreement

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by this Privacy Policy. By clicking the button to proceed, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore, the People’s Republic of China, Egypt, Turkiye, Malaysia, Brazil and Mexico.

Age Restriction

In order to use the Game Services, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

Brazil

This section applies to users located in Brazil:

Consent Revocation

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us at here. This may affect our provision of the Game Services to you.

Parental and Guardian Consent

If you are under the age of 18, you should not use the Game Services for any purpose without first obtaining parental/guardian agreement to this privacy policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES AND TRANSFERRING TO COUNTRIES OTHER THAN BRAZIL, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

United States

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information from or about you or your device:

Identifiers, such as your name as it appears on your social media profile, user ID, nickname, profile information, social media account ID and information, player/team user ID, QR code, IP address, device ID, device name, device token, user token, phone number, mailing address, email address, or a related advertising ID and device information. If you participated in one of our game-based events and won any physical prize, we processed your name (as shown on your passport), email address, telephone number, mailing address and postal code. If you registered for one of our tournaments, we processed your name, email address, country/region and user ID. If you registered for an e-sports event, we collected your team name, registration region, team logo, your name, nationality or residency, email address, Discord ID (if applicable) and user ID. If you qualified to attend in person an e-sports event, we also collected your ID or passport information, date of birth, gender, home address, phone number, photo and social media profile. If you have received suspensions for cheating or otherwise violating tournament or e-sports event rules, we collect your name, Game nickname (including variations) and day and month of birth. For data subject requests, we collected your alias, email address, screenshot of Game avatar, user ID, and if applicable, name of requestor, email address of requestor and proof of user's identity. This information is collected directly from you and your device, from social media platforms if you choose to sign up using a social media account or provide for customer support communications and, if applicable, the data subject request requestor on your behalf.
Internet or other electronic network activity information, such as your information regarding your use of the Game Services, including level, score, date and time stamps of actions, and log-in and clickstream data. If you have poor network connection, we collected your IP address and network speed. This information is collected directly from you and your device.
Device information, such as application version, battery level, available storage, list of installed applications, OS version, carrier, device language, device name, device resolution, manufacturer, and device model. This information is collected directly from you and your device.
Social connections, such as names of your friends if you choose to log-in using a social media service and friend interaction information. This information is collected from social media platforms if you choose to sign in using a social media account.
Game-related data, such as Game server, gameplay mode information, number of kills, movement speed, date and time stamps of actions, registration time, number of visits, VIP level, game duration, historical records, items, currency, penalties, logins, activities, recharge, purchases, in-game friend relationships, game match data, in-game preferences, screenshots of your in-Game view, UGC map information, game experience, level and game credit score, and statistics (such as play count, save count and follow count) relating to certain Game Services. This information is collected automatically when you use the Game Services.
Communication data, such as your chat data if you enable chat service or your communications with customer support. This information is collected directly from you.
Commercial information about any transactions and refund requests in the Game or via a third party such as what products were purchased, how much they cost, if they were used and transaction identifiers. This information is collected directly from you and your device and the Google Play or Apple iOS store or the third party where you made the purchase.
Geolocation data such as your region location when you set up your profile for the Game Services, area ID (region), and your province and city if you choose to use region-specific or birthday features. This information is collected directly from you.
Audio and visual information such as your social media profile picture, avatar, audio self-introduction, photos shared in the Game or uploaded by you to the Game, work(s) uploaded, in-Game screenshots, UGC map displays and recordings, battle and replay videos, audio messages, and tournament and event video and audio recordings. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.
Professional or employment-related information such as your profession if you choose to provide it in a survey. This information is collected directly from you.
Other information described in subdivision (e) of Section 1798.80, including information about your gender, nationality, or age. This information is collected directly from you in the context of being our consumer.

We collect and disclose your personal information, including sensitive personal information, for the following purposes:

To provide you the Game Services, including offering the Game and Websites, maintaining your account, providing customer service, providing region-specific features, providing the World of Wonder creative mode and related features and programs, generating highlights replay videos, generating season and anniversary reviews, processing payments and refunds, facilitating your sharing of screenshots on social network, enabling you to use or customize the Club features, enabling you to customize your in-Game photo wall, sending you communications, and delivering audio and text messages;
To register you for and arrange e-sports events, tournaments and community events;
To process surveys and administer sweepstakes;
To display battle replay videos of top players and broadcast tournament livestreams;
To verify eligibility for participation in our Game Services and Beta test;
To enable you to connect with your friends and share information and game activities with your friends;
To provide UGC map features;
To provide Website events;
To send you your prize if you win any during our events, programs or tournaments;
To provide you with feedback and information about your gameplay and progress;
For marketing and publicity purposes;
If you participate in Game competitions on the FACEIT service, to facilitate your use of the service;
For data subject requests, to verify your identity, your rights and to process the requests;
To improve our services, including the functionality of the Game Services;
To monitor the success of our advertising and marketing programs;
To ensure the integrity of the Game Services, to protect users from prohibited conduct and to maintain a fair gaming environment within the Game;
For security and verification purposes, including to prevent and detect fraudulent activity;
To address and remediate technical issues and bugs; and
To enforce our terms, conditions and policies.

For additional information about what each type of personal information is used for, see this chart in the main portion of the privacy policy.

We disclose each of the categories of personal information that we collect as described in Section 3 (How We Store and Disclose Your Personal Information).

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the CCPA, and we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws. In the past 12 months, we may have collected the following types of sensitive personal information about you:

· Your chat data

Retention of Your Personal Information

The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.

Rights under US State Laws:

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:

the categories of personal information about you that we collected;
the categories of sources from which the personal information was collected;
the business or commercial purposes for collecting personal information about you;
the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
the specific pieces of personal information we collected about you;

Right to Delete. Request we delete personal information we collected from you;
Right to Correct. Request we correct inaccurate personal information that we maintain about you;
Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data by contacting us at here. We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need you to provide the Data Subject Request Information set out in the section “How We Use Your Personal Information”.

Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

Questions

If you have questions or concerns regarding this Privacy Policy, please contact us using the details provided here.

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, please contact us using the details provided here. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this privacy policy.

Colombia

How We Use Your Personal Information

From the entry into force of this Privacy Policy, at the time of the collection of your personal data, we will request your prior authorization, by informing you about the specific purposes of the processing of your personal data for which such consent is obtained under the Privacy Policy.

Your authorization may be expressed (i) by writing, (ii) orally or (iii) through unequivocal conducts that allow us to reasonably conclude that your authorization was granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

Your Rights

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information.

You can contact us if you want to exercise any of these rights through our contact information in the section ‘Contact & Complaints’ of this Privacy Policy.

Proceedings For The Exercise Of Your Rights

Queries (rights to access): You can file queries regarding the processing of your personal data by us.

Claims (right to correction and erasure): You have the right to file claims in relation to the processing of your personal data by clearly describing the facts that give rise to your claim.

Egypt

This privacy policy is provided in Arabic for users located in Egypt. In case of dispute, the Arabic version of this privacy policy shall prevail.

By clicking the button to proceed or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this privacy policy. If you do not consent to this privacy policy, you must not use the Game Services.

You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular Singapore, the People’s Republic of China, Egypt, Turkiye, Malaysia, Brazil and Mexico.

You also acknowledge your consent to receiving marketing messages from us, whether through e-mails or pop-ups or other such means.

If you are a new user, you have seven days to inform us of any objection you may have to this privacy policy.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

France

Your Rights

Instructions for the processing of your personal data after your death

You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death.

The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent.

You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us using the details provided here.

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

Age Restrictions

Parental consent is required for children under the age of 18 years to use our services.

Sensitive Personal Information

Sensitive Personal Information under local law includes passwords, financial information (such as bank account, credit card, debit card or other payment instrument details), biometric data, physical or mental health, sex life or sexual orientation, and/or medical records or history, but does not include information available in the public domain, or provided under Indian laws, including the Right to Information Act, 2005.

Sharing Of Your Sensitive Personal Information

Where we permit any third parties to collect and use Sensitive Personal Information, we shall use reasonable measures to ensure that the third parties do not further disclose the Sensitive Personal Information to the extent required by applicable laws.

Withdrawal Of Consent

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at here. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.

Indonesia

Consent

By accepting and consenting to this privacy policy, you agree that we may collect, use and share your personal information in accordance with this privacy policy, as revised from time to time. If you do not agree to this privacy policy, you must not access or use our services and we have the right to not provide you with access to our services.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on the Game and use the Game Services.

Data Subject Rights

You have the right to access your personal information stored in our Game from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the Game Services, we will notify you through the contact information provided by you or via the Game Services, to the extent required by local laws and regulations.

Data Retention

We will retain your personal information in line with legal requirements.

Data Accuracy and Third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Kazakhstan

If you are under the age of 18, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Game Services.

By accepting this Privacy Policy, you consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information as described in this Privacy Policy. The transfer of your personal information to third parties, which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore, the People’s Republic of China, Egypt, Turkiye, Malaysia, Brazil and Mexico.

Your Rights

· Right of access: You have the right to request access to and obtain a copy of the personal information we have process about you or that is being processed on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

· Right to correction: You may request for the correction of your personal information or delete such personal information if it is impossible to correct it. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

· Right to blocking / de-blocking: You have the right to request the blocking of personal information related you, if you become aware of a violation regarding the collection and processing your data. If the violation has not been proved, you may request to de-block your data.

· Right to deletion: You have the right to request deletion of your personal data if the collection and processing of your data has been conducted in violation of Kazakh laws.

· Processing of your personal information in public sources of personal data: You may request to limit or provide your consent on the processing of your personal information in public sources of personal data.

Kingdom of Saudi Arabia

How We Store and Share Your Personal Information

Your personal data may be transferred abroad and to third parties as follows:

Identity of the overseas recipient	Location of the recipient (or as otherwise stated in the recipient’s privacy policy)	Purposes of use of Personal Information by the recipient	Items of Personal Information to be provided
Aceville Pte. Ltd.	Singapore	Storage of personal information	All personal information as set out in the section “How We Use Your Personal Information”
	Hong Kong and Singapore	User authentication	Captcha Data as set out in the section “How We Use Your Personal Information”
	Hong Kong and Singapore	Sending of SMS verification codes	Telephone number, country code and SMS content
Functional Software, Inc. d/b/a Sentry	United States and other countries where Sentry or its affiliates, future subsidiaries or service providers maintain facilities	Crash analysis	User ID, device model, OS version, exception stack and exception log, network type, memory information
Google LLC	Any country in which Google or its sub-processors maintain facilities	Storage of personal information	Tournament Player Suspension Information as set out in the section “How We Use Your Personal Information”
Google LLC		Speech-to-text function (all languages except Chinese and English)	User-generated content (audio converted to text)
CEC GienTech Technology (Shenzhen) Co., Ltd.	People’s Republic of China	Identify abuse, harassment, plug-in sales or other uses of chat in violation of our End User License Agreement; assist us in improving tools we use to identify such violations	Reported chat data (including the anonymised voice file)
GameStars Inc.	United States	Provide Online platform for eSports events	eSports Website Event Registration Information
Shenzhen Baby Elephant Entertainment Culture Entertainment Co., Ltd	People’s Republic of China	Process payments for cash prizes	Game-based Event Information (cash prizes)
Firebase	USA	Send push notifications User acquisition and to monitor the effectiveness of our advertisements	Push notification data Advertising Information (Firebase)
Meta	USA	User acquisition purposes and to monitor the effectiveness of our advertisements, and analytics	Advertising Information (Meta)
Google Cloud Platform	Germany	Storage of personal information	Email subscription data, email segmentation data and email engagement performance data
Amazon Web Services (AWS)	Singapore and United States	Email sending, email engagement performance analysis and determination of health of AWS account	Email subscription data and email events
Midas	Singapore	Provide payment function To ensure the security of our services	Transaction Records, Transaction Identifiers, Refund information, and Security and Operation Information

Transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.

Your Rights

You have the right to be informed about our processing of your personal information, which we satisfy by providing this Privacy Policy to you. You also have the following rights as further described in Section 6 (Your Rights): the right to access, correction, erasure, restriction and to withdraw consent. Unless otherwise stipulated by law in Saudi Arabia, you will not be required to pay any fees in return for exercising these rights. We will respond to your request within 30 days of receiving it. Where you wish to make such requests, please contact us as set out in Section 7 (Contact).

You also have a right to lodge a complaint with the Saudi Data and Artificial Intelligence Authority by contacting them directly. Their website is accessible at: www.sdaia.gov.sa

Data Destruction

Personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

Kuwait

You represent that you are at least 21 years old, or 18 years old and have obtained parental/guardian consent and, therefore, legally capable of contracting under the applicable laws and regulations in Kuwait.

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Macau SAR

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Game Services to you. As a Macau SAR data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

Parental and Guardian Consent

If you are under the age of 18, please do not use the Game Services.

In the event you are agreeing to this privacy policy in order for a minor to access and use the Game Services, you hereby consent to the provision of personal information of the minor to be processed in accordance with this privacy policy and you personally accept and agree to be bound by the terms in this privacy policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this privacy policy.

Your Rights

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requestor to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requestor to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the Game Services to you.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Our data protection officer, responsible for the management and safety of your personal information

You can reach us using our Online form here
Phone: +603-22872388

Mexico

Age Restrictions

Please do not use the Game Services unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf).

Types of Personal Information We Use

For clarification purposes, in section "The Types of Personal Information We Use” and section “How We Use Your Personal Information” you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations.

Purposes of Processing

Some of the purposes of processing stated above are for voluntary purposes, including to show you personalised recommendations. We may also use your personal data for the voluntary purpose of sending information to your email or SMS that we may consider relevant to you. You may object to the processing of your personal data for voluntary purposes as stated in the section “Your Rights” below.

Please be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and carry out the transfer of personal data detailed in section “How We Store and Disclose Your Personal Information”.

Data Transfer Consent

In general, we do not require your consent to carry out the transfers detailed in section “How We Store and Disclose Your Personal Information”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.

By using the Game Services and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section “Your Rights” below.

Your Rights

The sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only”, which include limitation to the use and disclosure of your personal data, and “Email Opt-Out” and “SMS Opt-Out” included in Section “Your Rights” above also apply to users that are located in Mexico. You also have the right to revoke the consent that you have provided us to process your personal data.

To exercise any of your rights, contact our Data Protection Officer using our Online form here.

To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our Data Protection Officer using our Online form here.

Cookies

Through the use of cookies, we collect certain information related to your browsing and device, some of which may be considered personal data (detailed in our Cookies policy here). You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, you should consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionalities of the Game Services may no longer be available to you. For more information about our use of cookies and how to disable them, please visit our Cookies policy here.

Morocco

The protection of your privacy is an important principle for us. We collect information for purposes strictly necessary for the proper use of the Game Services.

By accepting these conditions of use, you explicitly accept that your personal data may be subject to processing by the Game Services.

Kindly note:

· the identity of the Data Controller is Proxima Beta Pte. Limited, please contact us using the details provided here.

· the purposes of the processing for which the data is intended are set out in the table in the section “How We Use Your Personal Information”.

· recipients or categories of recipients are set out in the second paragraph of the section “How We Store and Disclose Your Personal Information”.

· whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to the section “How We Use Your Personal Information” and the section “Your Rights” (sub-paragraph “Objection”).

New Zealand

This section applies to users located in New Zealand:

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

Correction

You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at here.

Children

If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game Services.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

Data Transfers

Peru

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Data Protection Law (the “Law”).

You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

Contact

Data Protection Team, responsible for the management and safety of your personal information
Contact: You can reach us using our Online form here.

Philippines

Minimum Age

You must be at least 18 years of age to be able to use the Game Services.

Your Rights

You are entitled to the following rights:

Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

Consent

By consenting to this Privacy Policy, you consent to us:

· collecting and processing your personal information as described in the section “How We Use Your Personal Information” above;

· sharing your personal information with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and

· transferring or storing your personal information in destinations outside the Philippines as described in the section “How We Store and Disclose Your Personal Information” above.

Qatar

If you are using the Game Services in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Russia

If you are using the Game Services in Russia, this section “Russia” applies to you. By using the Game Services:

you consent (for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations) to the processing in accordance with this privacy policy of your information; if legitimate interests, optimisation of the Game Services, carrying out of the contract or other grounds are mentioned herein as grounds for the processing of data, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies in accordance with our Cookies policy (to the extent that those qualify as personal data under Russian law);
you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular Singapore, the People’s Republic of China, Egypt, Turkiye, Malaysia, Brazil and Mexico;
you agree (for the purposes of Article 152.1 of the Russian Civil Code) with the processing of your image/photo in accordance with this privacy policy; and
you consent, for the purposes of Federal Law “On Marketing/Advertising”, that we may share advertising/marketing communications with you, unless you have opted-out from such communications.

The sub-sections “Access”, “Correction”, “Erasure”, “Restriction of Processing to Storage Only”, “Objection”, “Email Opt-Out” and “SMS Opt-Out” of the section “Your Rights” above apply to users in the Russian Federation.

We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Game Services after the notification.

As regards the representative for Russia, you can contact us at here. Please include the word “Russia” in the subject line of your email.

Separate consent for using certain data

For the purposes of the operation of the Service, as part of its activities, we do not distribute (publicly disclose) personal data without the appropriate consent of the data subject and in compliance with the requirements of Article 10.1 of Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended).

By using the Game Services you also consent to the sharing of your personal information with certain third parties for the purposes set out under section “How We Store and Disclose Your Personal Information”.

You determine, in your discretion, the terms of disclosure to the general public of your personal data, by choosing to use certain features of the Game Services and by choosing the appropriate privacy settings in respect of your personal information in the Game Services.

We process your personal information subject to the terms of this Privacy Policy and your chosen features and settings.

This consent is granted for as long as you use the Game Services. The consent may be withdrawn by you (and you may set any restrictions on processing of your relevant personal information) at any time by contacting us (using our Online form here): please include the word “Russia” in the subject line of your email.

Serbia

Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.

Name: Karanovic & Partners o.a.d. Beograd
Address: Resavska 23, Belgrade, 11000, Serbia
Telephone Number: +381 11 3094 200
E-mail: local.representative@karanovicpartners.com

Singapore

By clicking the button to proceed, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the People’s Republic of China, Egypt, Turkiye, Malaysia, Brazil and Mexico.

Access

You have the right to access your personal information, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at here.

Correction

You have the right to correct any of your personal information that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact here.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at here.

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Sri Lanka

By clicking the button to proceed, you consent to the terms and conditions of the Privacy Policy and permit the collection, use and disclosure of your personal information. However, if you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game Services.

Where you request to withdraw consent, refrain from further processing of data, erase, rectify or complete your personal information, we will provide you with our response to the request within 21 working days.

Thailand

By accepting this privacy policy, you acknowledge that you have read, understood, and agree to this privacy policy. If you do not agree with this privacy policy, you must not use the Game Services.

If you are under the age of 20, you undertake that you have obtained your parent or legal guardian’s consent to register an account on and use the Game Services.

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

· withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;

· request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;

· request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or

· lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us at here.

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in the section “Contact Information” and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

Türkiye

Our Data Controller Representative in Türkiye for the purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations, Özdağıstanli Ekici Avukatlık Ortaklığı, can be contacted at turkeydatarep_proximabeta@iptech-legal.com. Please include the word “Türkiye” in the subject line of your email.

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

learn whether or not your personal data has been processed;
request information about processing if your personal data has been processed;
learn the purpose of processing of your personal data and whether they have been used accordingly;
know the third parties in the country or abroad to whom personal data has been transferred;
request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems, and
demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

Identity of the overseas recipient	Location of the recipient (or as otherwise stated in the recipient’s privacy policy)	Purposes of use of Personal Information by the recipient	Items of Personal Information to be provided
Aceville Pte. Ltd.	Singapore	Storage of personal information	All personal information as set out in the section “How We Use Your Personal Information”
	Hong Kong and Singapore	User authentication	Captcha Data as set out in the section “How We Use Your Personal Information”
	Hong Kong and Singapore	Sending of SMS verification codes	Telephone number, country code and SMS content
Functional Software, Inc. d/b/a Sentry	United States and other countries where Sentry or its affiliates, future subsidiaries or service providers maintain facilities	Crash analysis	User ID, device model, OS version, exception stack and exception log, network type, memory information
Google LLC	Any country in which Google or its sub-processors maintain facilities	Storage of personal information	Tournament Player Suspension Information as set out in the section “How We Use Your Personal Information”
Google LLC		Speech-to-text function (all languages except Chinese and English)	User-generated content (audio converted to text)
CEC GienTech Technology (Shenzhen) Co., Ltd.	People’s Republic of China	Identify abuse, harassment, plug-in sales or other uses of chat in violation of our End User License Agreement; assist us in improving tools we use to identify such violations	Reported chat data (including the anonymised voice file)
GameStars Inc.	United States	Provide Online platform for eSports events	eSports Website Event Registration Information
Shenzhen Baby Elephant Entertainment Culture Entertainment Co., Ltd	People’s Republic of China	Process payments for cash prizes	Game-based Event Information (cash prizes)
Firebase	USA	Send push notifications User acquisition and to monitor the effectiveness of our advertisements	Push notification data Advertising Information (Firebase)
Meta	USA	User acquisition purposes and to monitor the effectiveness of our advertisements, and analytics	Advertising Information (Meta)
Google Cloud Platform	Germany	Storage of personal information	Email subscription data, email segmentation data and email engagement performance data
Amazon Web Services (AWS)	Singapore and United States	Email sending, email engagement performance analysis and determination of health of AWS account	Email subscription data and email events
Midas	Singapore	Provide payment function To ensure the security of our services	Transaction Records, Transaction Identifiers, Refund information, and Security and Operation Information

Ukraine

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries or regions other than Ukraine, to the extent and for the purposes provided in this Privacy Policy.

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws) and storage of your personal information, as described in the privacy policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

PRIVACY FAQ

IN-GAME CHAT SAFETY FUNCTION

1. Introduction

We take your data privacy and security very seriously. We take steps to ensure that your content is stored and processed by us in a transparent way and using secure and reliable technology.

We understand that your trust is something we earn. As part of that process, we work to keep you informed of our data privacy policy and measures, as they may change over time.

This FAQ explains some common questions on a feature for certain regions concerning chat of PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE (“Game”), particularly for those users and prospective users who have questions about how we meet our requirements under data protection laws and other applicable regulations concerning data privacy.

For further information regarding our data privacy practices and this FAQ:

(a) Please review the PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE Privacy Policy – which sets out how we collect, store and process your personal data to provide you with the Game, and the End User License Agreement for PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE.

(b) Please contact our privacy team using our Online form here should you have any further questions.

2. What is the in-game chat safety function?

To ensure the Game provides a safe platform for users of the Game, we have introduced an in-Game chat safety function (“Safety Feature”) in certain regions. The Safety Feature helps us to improve your experience of the Game by flagging users who use chat function in violation of our End User License Agreement . For countries where the law requires that we have a legal basis for processing certain data, we operate the Safety Feature in our legitimate interests to ensure the safety and integrity of our Game. The Safety Feature works to identify, for example, unsolicited commercial communications, including plug-in sales and advertising, spam, harmful communication, exploits, bullying, harassment, threats of violence or conduct which is hateful, harassing, abusive, racially or ethnically offensive, defamatory, humiliating, threatening, profane or similarly objectionable (“Prohibited Conduct”).

3. What are the consequences for users who engage in Prohibited Conduct?

All users are required to comply with our End User License Agreement , and you should familiarize yourself with your obligations as part of our gaming community. In order to ensure a safe gaming environment for our users we may take action against users who violate the End User License Agreement or otherwise engage in Prohibited Conduct, which may include limiting use of those features that have been abused.

4. How can I use the Safety Feature and how does it work?

When you observe a user engaging in Prohibited Conduct, you can press the “Report” button on the screen if this feature is available in your region. This will record a short snippet of the chat, and for voice chat, convert it into text at the same time or store the last 30 seconds of the voice chat on our servers. The chat data may be automatically translated if needed. The chat data will be reviewed for Prohibited Conduct and, in certain regions, for improvement of the tools we use to identify violations.

5. What if I think I have been implicated by mistake?

We have implemented safeguards to ensure any consequences are appropriate and proportionate to the relevant Prohibited Conduct and the frequency with which such Prohibited Conduct has occurred.

We will notify you if you have been muted or restricted from sending chats as a result of your breach of the End User License Agreement . If you think your use of the chat functions was restricted by mistake, please contact us at service@pubgmobile.com to request a review.

6. Do you warn users before taking action?

We may not issue a warning before restricting your use of the chat functions but we will notify you if restrictions are made.

7. Do you store chats and where do you store them?

The Safety Feature is designed to protect your privacy. Documented chat and the clip (for voice chat) is not stored, except where the information provides evidence of Prohibited Conduct by a user. In these cases we store the documented chat as evidence, and in certain regions we also store the documented chat and voice file in anonymized form for improvement of the tools we use to identify violations, on our servers in Singapore and subsequently automatically delete it in accordance with our Privacy Policy.

8. Do you disclose chats to any third parties?

We do not disclose any chats of any user to any third party, except where necessary for the review and translation process and to assist us in improving our anti-cheating tools, or in exceptional circumstances, such as where we believe we are legally required to (for example, if we are subject to a court order for disclosure), or where we need to do so in order to enforce or protect your rights, our rights or the rights of other users. Please consult our Privacy Policy for further details.

9. Can I object to your processing of my chats?

Yes. If you are a resident of a relevant country as noted in our Privacy Policy, you may have the right to object to, and seek restriction of, our processing of your chats for this purpose. To exercise your right, please contact us at here and please consult the Privacy Policy for further information.

We will consider several factors when assessing an objection, including: our users' reasonable expectations; the benefits and risks to you, us, or other users as a result of our implementation of the Safety Feature; and other available means to achieve the same purpose the Safety Feature achieves that may be less invasive and do not require disproportional effort. Unless the processing is based on our compelling legitimate grounds or is needed for legal reasons, your objection will be upheld and we will cease processing your information.

10. Is the Safety Feature secure and how do you comply with data protection laws?

We have a comprehensive global privacy program directed at protecting your personal data. You can read about how we process and protect personal data in our Privacy Policy. We also use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorized access or disclosure of your information.

11. How do you respond to law enforcement requests for chat information?

We may, from time to time, receive law enforcement requests to disclose your chat information (and its translation) to regulators, courts or law enforcement bodies. When we receive these requests, we take reasonable steps to query them and establish whether or not we are legally required to respond to them. When we are legally required to respond to such a request, we will take measures to safeguard your legal rights and your personal data.