PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE

Privacy Policy

Last Updated: 22 JULY 2020 

Thank you for using our 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 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, and to provide you with game updates. We do not share your information with 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 we are instructed to by a court, authority or compelled by law. More Information.

Who do we share your information with?

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 India (in the case of users located in India only), Singapore, Hong Kong SAR and the United States. In addition, our support, engineering and other teams located in our offices around the world (including the People’s Republic of China (“PRC”) (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong SAR and Macau SAR), India (in the case of users located in India only), the United States and Hong Kong SAR) will have access to your information. 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 Email: dpo@proximabeta.com

EU Representative: Tencent International Service Europe B.V. Email: eudataprotection@tencent.com

Turkey Representative: Özdağıstanli Ekici Avukatlık Ortaklığı. Email: dpo@proximabeta.com

Thailand Representative: Tencent (Thailand) Limited Email: dpo@proximabeta.com

Welcome to PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE!

This privacy policy explains the when, how and why when it comes to processing of your personal information in connection with the mobile game PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE (“Game”) and the website for the Game (“Website”), 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 or the Website (the “Game Services”) you are accepting our rules regarding your personal information as described in this privacy policy.

This Game has been developed by the Tencent group (“we”, “us”, “our”). For the purpose of EU data protection laws, the data controller of your personal information in relation to the Game Services is Proxima Beta Pte. Limited, which is a Singapore-based company within the Tencent group. The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore. Our representative in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V., a company registered in the Netherlands, with the registered address at 26.04 on the 26th floor of Amstelplein 54, 1096 BC Amsterdam, the Netherlands and can be contacted at eudataprotection@tencent.com. Our data protection officer can be contacted at dpo@proximabeta.com.

Our representatives in certain jurisdictions are as follows:

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at dpo@proximabeta.com.

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.

The following is a high level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party). 

You give us information about you when you register for the Game (your nominated nickname, and information we import from your connected social media account (WeChat, Facebook, QQ, VKontakte, Twitter, Google Play, Game Center or LINE) in order to set up your profile, including your name as it appears on your social media profile, your user ID and your profile picture). You also provide us with information when you set up your profile for the Game (including region location and information you voluntarily elect to provide in order to customise gameplay, such as gender) or your nickname when you log-in as a ‘guest’ in order to use the Game.

Once a Game account is set up, you may also choose to provide us with your mobile phone number or email address and a password, which you may select yourself for the purposes. These will be bound to your account (once verified by way of a verification code we will send to you) for the purposes of enabling login by email or mobile phone number. If you choose to bind your phone number or email address with your account, you will have the option to login via your mobile phone number or email address and we will access your phone number or email address to verify you as a user without you having to enter a validation code or password every time you login. For certain regions, we will ask you to bind your telephone number with your account when you change your location setting.

You also provide us with information when you participate in a survey in the Game (in which case we will process the information you provide to us as part of the survey, including country, age, gender, profession and email address). When you participate in one of our sweepstakes events you provide us with information including email address, Open ID, phone number, mailing address and country; and when you register for an e-sports event we will collect your team name, your name, nationality, proof of residency, email address, phone number and character ID. If you qualify to attend in person the global final of an e-sports event, we will also ask you for your passport and/or proof of residency information.

You provide us with your telephone number and/or email address if you choose to receive information on our game updates via email and/or SMS.

2. Information about you generated as part of the Game (and its in-Game services)

We automatically collect certain data from you when you use the Game Services, namely your open ID, IP address, device information (such as application version, battery level, WiFi strength, available space, network type, OS version, platform, carrier, country code, series ID, Android ID, MAC and IDFV), registration time, login time, and information regarding your use of the Game Services, such as date and time stamps of actions. We also collect and store your data:

· each time you interact with us, for example, when you use in-app or in-Game support to communicate with us;

· if you choose to log in using a social media service, we import the social media user ID and name of the friends (and in the case of Facebook, their Facebook nickname and profile picture) from your social media profile so that you can connect with your friends;

· if you click on a link that advertises the Game, we store the Advertising ID for that advertisement and select device information with your profile;

· if you enable chat services (audio and/or text and use them whether inside or outside a battle) then we will process such data in order to deliver your messages to other users;

· if you conduct any transactions within the Game or via a third party other than Google Play or iOS App Store, we collect information to facilitate your transaction and to maintain transaction records (including Open ID and user information cost, currency, product purchased, purchase history, IP address, details of transactions linked to player ID, and device details such as OS version, phone model or type of device, internet connection);

· if you change your location setting, we use your IP address to suggest your current location;

· if you contact our support team, we collect information including name (optional), Open ID, device ID, application version, battery level, WiFi strength, free space on device, network type, OS version, browser type, platform, carrier, country code, details of ticket, email address (optional if in-app/in-Game support) and any information that you provide in your communications. You also have the option of providing a photo to illustrate any errors; and

· when you are using the Game Services our security feature collects (in addition to the categories of data listed above) device information including the IMEI number and available memory; information about your internet connection including if applicable the WiFi name and MAC address of the WiFi access point; and a list of installed APK and running apps.

3. Information you generate and display in the course of using the Game Services.

You may provide additional information as part of your profile (such as gender). You may also provide or generate information when you communicate with other users in the Game (chat log data and chat content, both audio and text). We generate an Open ID and use this to store your Game data, and we collect and store your Game play statistics (e.g. level, scores) in order to provide you with feedback and information about your Game play and progress. If you participate in a sharing event, we will process your Game data (prop types, wins, ranking and Game play statistics) to prepare a report for you.

Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Game Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the Game) or web browser (in the case of the Website) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game Services may be unable to operate as designed.

For more information about our Cookies policy, click here.

Children

Our Game Services are not intended for children. Children must not use the Game Services for any purpose. By children, we mean users under the age of 13 years old; or in the case of users located in a country listed in the table below, the relevant age listed for that country.

*Users located in this country and who are under the minimum age are required to obtain parental/guardian consent prior to the playing of the Game.

**In the case of users located in the European Economic Area and Switzerland, persons under the age of 16 may use the Game Services if parental/guardian consent is obtained prior to using the Game Services.

***In the case of users located in the United Arab Emirates, the minimum age to be able to legally agree to commercial transactions is 21 (under the Hijri calendar). However, a minor, who is between the ages of 18 and 21 may obtain a court order giving him/her permission to engage in specific commercial transactions. In addition, a minor who is above the age of 7 years old may engage in commercial transactions subject to their guardian’s approval.

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, please contact us at dpo@proximabeta.com and we will delete such information.

How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the United Kingdom, European Economic Area or Thailand (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

We may collect other personal information from you from time to time for specific reasons (such as a promotion in your country). When this happens, we will provide more information on any specific changes to the way we process that personal information that might differ to this privacy policy prior to collecting or processing any additional information. In some cases, that information may be shared with us with your consent – and if that is the case, we will provide you with further information on how we process that information and your rights.

How We Store and Share Your Personal Information

The Tencent 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. In addition, our support, engineering and other teams are located in our offices around the world (including the People’s Republic of China (“PRC”) (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong SAR and Macau SAR), the United States and Hong Kong SAR) and will have access to your information. 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:

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

· Hong Kong SAR;

· Singapore; and

· the United States.

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 the United States and 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 share your personal information with third parties. Situations where this occur are:

· Third parties that provide services in support of the Game Services, including providers of cloud services that process or back up information identified in this privacy policy on their servers for the purpose of providing the Game Services (including the sharing of in-game photos on WeChat, Facebook, VKontakte, QQ, Twitter, Google Play, Game Center or LINE (as applicable)), for the purpose of processing customer support ticket IDs and support communication, for the purpose of providing marketing and advertisements and monitor 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 arranging e-sports events, and payment processing services (including security and fraud detection). 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 the Tencent 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. There are circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users.

· A third party that acquires all or substantially all of us or our business. If we sell or buy any business, undergo a merger, enter into a partnership, or sell some or all of our assets we may disclose your information to the prospective buyer of such business. Under these circumstances, we will always require the prospective buyer to comply with this privacy policy.

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 implement and maintain reasonable security measures to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

Data Retention

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.

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 Brazil, Canada, India and Russia.

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

You have certain rights in relation to the personal information we hold about you. 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 email us at dpo@proximabeta.com.

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 Game account. If you believe we hold any other personal information about you, please contact us at dpo@proximabeta.com.

Portability

You have the right to receive a copy of certain personal information we process about you. 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 access the personal information we hold about you by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo@proximabeta.com. 

Erasure

If there is any personal information you believe we process that you would like us to erase, please contact us at dpo@proximabeta.com.

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 dpo@proximabeta.com.

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 dpo@proximabeta.com. 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 from us by following the unsubscribe instructions included in these emails or you can contact us at pubgmobile_cs@tencentgames.com.

SMS Opt-out

You may opt out of receiving game update marketing or advertising text messages by contacting us at pubgmobile_cs@tencentgames.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 Game access 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. 

Contact & Complaints

We welcome questions, comments and requests regarding this privacy policy. Please address them to dpo@proximabeta.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo@proximabeta.com and 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 country in which you live or work where you consider we have infringed data protection laws.

Changes

If we make any material changes to this privacy policy, we will post the updated policy here and notify our users within the Game. Please check this page frequently to see if there are any updates or changes to this privacy policy.

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.

Brazil

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.

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

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed 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, open ID / user ID, IP address, device ID, device token, phone number, mailing address, email address, nickname or a related advertising ID and device information. If you qualified for certain e-sports events, we also collected your passport and/or proof of residency. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.

· 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. This information is collected directly from you and your device.

· Commercial information about any transactions in the Game or via a third party such as what products were purchased and how much they cost. 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. This information is collected directly from you.

· Audio and visual information such as your social media profile picture, photos shared in the Game, and audio messages. 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 your personal information for the following purposes:

· To provide you the Game Services, including offering the Game, maintaining your account, providing customer service, processing payments, and delivering audio and text messages;

· To register you for and arrange e-sports events;

· To process surveys and administer sweepstakes;

· To improve our services, including the functionality of the Game;

· To monitor the success of our advertising and marketing programs;

· For security and verification purposes, including to prevent and detect fraudulent activity;

· To address and remediate technical issues and bugs.

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 personal information to the following types of entities:

· Other companies within the Tencent corporate group who process your personal information in order to operate the Game Services

· Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us

· Regulators, judicial authorities, law enforcement agencies and other third parties where reasonably necessary to comply with a legal obligation; enforce our terms and conditions; detect and prevent fraud or security issues; and to protect ours and others’ rights, property or safety

· Entities that acquire all or substantially all of our business

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

Rights under the CCPA

If you are a California resident, you have the right to:

· Request we disclose to you free of charge the following information covering the 12 months preceding your request:

o the categories of personal information about you that we collected;

o the categories of sources from which the personal information was collected;

o the purpose for collecting personal information about you;

o 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

o the specific pieces of personal information we collected about you;

· Request we delete personal information we collected from you, unless CCPA recognizes an exception; and

· 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 CCPA.   

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, to other data by contacting us at dpo@proximabeta.com. 

Canada

Service providers

If a user located in Canada wishes to obtain written information about our policies and practices with respect to our service providers located outside Canada, they may contact us at dpo@proximabeta.com. 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.

India

SHARING OF YOUR PERSONAL INFORMATION

Where we permit any third parties to collect and use your Personal Information, we shall take reasonable measures to ensure that the third parties do not further disclose the Personal Information.

AGE RESTRICTIONS

Children under the age of 18 are not allowed to execute online contracts with us or sign up for our services. Parental consent is required for children under the age of 18 years to avail our services.

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 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, we will notify you through the contact information provided by you or via the Game, to the extent required by local laws and regulations, at the latest 14 days since we acknowledge the breach of confidentiality.

Data Retention

Notwithstanding the provision on the erasure of personal information, to the extent required by local laws and regulations, we will retain your personal information, at the latest for five years.

Notification to Amendment of this Privacy Policy

In the event we amend this policy, we will ask you to acknowledge the changes through a pop-up notification or the splash screen on our mobile app. If you fail to explicitly express your objection to the amended policy within the above notification period, you will be considered as accepting the changes and agreed to the new policy. However, you may stop using or accessing our Service by unsubscribing at any time, if you cease to agree with the changed policy.

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).

Malaysia

Language of this Privacy Policy

In the event of any discrepancy or inconsistency between the English version and Malay version, the English version shall prevail.

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.

Rights of Data Subjects

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 requester 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 requester 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

Email: dpo@proximabeta.com

Russia

If you are using the Services in Russia, by using the 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 Service, 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, your 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 the 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 as set out in this privacy policy to any country where we have databases or affiliates and, in particular Hong Kong SAR, Singapore, the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong SAR and Macau SAR) and the United States;

· 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” of the section “Your Rights” above apply to users in the Russian Federation.

We will not implement any material changes to the way we process your personal information, as described in the privacy policy, unless we have notified you. We will notify you of any such material changes and may request you to acknowledge such changes. Unless we require the acknowledgment, you shall be deemed to have agreed to the changes, if you continue using the Services upon the notification.

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

Thailand

By clicking “accept” or by proceeding with the sign up process, 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.

You may withdraw your consent to the processing of your personal information. You may request us to provide access to, make any correction to, discontinue, restrict the use or provision of, erase any and all of your personal information and/or provide you or transfer to third party such information which is stored by us in a machine readable format as well as file a complaint to a relevant authority, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at dpo@proximabeta.com.

We will ask you to acknowledge any material changes to this privacy policy through a pop-up notification or the splash screen of our mobile app, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

Turkey

Our Data Controller Representative in Turkey for the purpose of compliance with Turkish Law on Personal Data Protection Law and its secondary regulations can be contacted at dpo@proximabeta.com. Please include the word “Turkey” in the subject line of your email.

You have legal rights in relation to the personal information data we hold about you. As a Turkish data subject, you may have right to (and to the extent permitted under applicable laws and regulations):

a) learn whether or not your personal data has been processed;

b) request information about processing if your personal data has been processed;

c) learn the purpose of processing of your personal data;

d) know the third parties in the country or abroad to whom personal data has been transferred;

e) request rectification in the event personal data is incomplete or inaccurate;

f) request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the Personal Data Protection Law (Turkey);

g) object to certain processing of data, and seek certain remedies in accordance with the Personal Data Protection Law (Turkey).

United Arab Emirates

You consent to the collection, use, disclosure, transfer and storage of your Personal Information.

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 also 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.

Vietnam

By accepting this privacy policy, you expressly agree and authorize us to collect, use, store, and process your personal information, including lawfully disclosing and transferring it to third parties, as described in this privacy policy.

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop processing or providing your personal information to a third party.