PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE

Privacy Policy

Last Updated: July 14 2023

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 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, and to provide you with game updates. 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 Russia (in the case of users located in Russia only), Singapore and the United States. 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, Indonesia and the United States. 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 hereMore Information.

Contact Information

Data ControllerProxima Beta Pte. Limited | Email: dpo@proximabeta.com

EU RepresentativeProxima Beta Europe B.V. | Email: dpo@proximabeta.com

UK Representative: Image Frame Investment (UK) Limited | Email: dpo@proximabeta.com

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

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

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 whenhow and why when it comes to the processing of your personal information in connection with the mobile game PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE (“Game”), the website for the Game (“Website”) and the eSports Website for the Game (“eSports Website”) (the Game, the Website and the eSports Website 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”). 

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 at dpo@proximabeta.com.

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

dpo@proximabeta.com

UK

Image Frame Investment (UK) Limited

Suite 1, 3rd Floor, 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB

dpo@proximabeta.com

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

dpo@proximabeta.com

Türkiye

Özdağıstanli Ekici Avukatlık Ortaklığı.

Nidakule Ataşehir Kuzey

Begonya Sok. No:3 Kat. 17 D: 162

34746 Ataşehir / İstanbul, Türkiye

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 at dpo@proximabeta.com.

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 Informationbelow.

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). For certain regions, you may also be asked to provide us with your date of birth (stored device-side only) to verify your age and for administration of the gameplay management system. If you are located in certain regions, we may ask you to provide an email address for the purpose of verifying parental or guardian consent to use the Game services if you are under the relevant minimum age. 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 these 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. If you choose to bind your phone number, you can also enable two-factor authentication. Once enabled, we will verify additional data for authentication if you log in from a new device. If you choose to bind your email address, we will send an account security alert to your email address if we detect any suspicious activity. If you need to recover your account, we will ask you questions to verify your identity. If you would like to be featured on leaderboards, you will also be asked to bind your mobile phone number. For certain regions, we will ask you to bind your telephone number with your account when you change your location setting.

 

In addition, you may choose to provide your location (province and city) to use region-specific features, for example, our Battle Zone Leaderboard, People Nearby, Regional Chat Channel and birthday features. If you would like to use our birthday features, you may provide your birthday (month and day) and location. You may add your in-game weapon preferences, game mode preferences, voice chat preferences, audio self-introduction and any other information to your calling card and share your calling card and QR code with other players, if these functions are available in your region. 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, which may be conducted in-Game, on our Website or otherwise, you provide us with information including email address, user ID, phone number, mailing address and country; when you register for a tournament, we will collect your name, email address, country/region and user ID; and when you register for an e-sports event, we will collect your team name, registration region, team logo, your name, nationality or residency, email address, Discord ID (if applicable) and user ID. If you qualify to attend in person an e-sports event, we will also ask you for your ID or passport information, date of birth, gender, home address, phone number, photo and social media profile. If you participate in tournaments or e-sports events, we will use your user ID, nickname, battle videos and audio and video recordings during matches to validate that you are the correct Game user, to investigate any allegation of cheating and for marketing and promotion. If you are suspended from participating in tournaments or e-sports events for cheating or otherwise violating tournament or e-sports event rules, we use your name, Game nickname (including variations) and day and month of birth to enforce the suspension and may publish your nickname, the reason for the suspension and the duration on our Websites or social media channels. If you participate in one of our game-based events, to send you digital prize(s) if you win such prize(s), we will process your email address and telephone number; to deliver physical prize(s) if you win such prize(s), we will process your name (as shown on your passport), email address, telephone number, mailing address and postal code; and if you share the event with your friends, we will process your friends list.

 

You provide us with your telephone number and/or email address and/or associated social media account information if you choose to receive information on our game updates via email and/or SMS and/or social media. Where applicable to your region, you provide your email address if you choose to receive information on our game promotions via email. You also provide information when you interact with a Q&A function or with our customer service team, including your contact information, any questions and images you submit and your social media platform information. For data subject requests, we collect information to verify your identity, your rights and to process the requests, including country/region, name, user email address, screenshot of user ID and user nickname, user ID, account registration date, login method, user nickname of linked social media account, account UC balance, account BP balance, request details, any other information necessary to verify your identity, and if the request is made by a requestor on your behalf, name of requestor, email address of requestor, requestor's relationship with you, proof of your identity and requestor's authority.

 

If you use the eSports Website, we need your Game login credentials to enable you to access eSports Website, your user registration information and account binding information to allow you to register as a player on the eSports Website and to participate in eSports events and team information to facilitate formation of teams.

 

If you would like to participate in Website events (if available in your region), we use your social media account information or email address to set up your account and your event registration information to register you for an event. If you win a prize at a Website event, we use your hashed nickname to announce your win and, in case of (i) an in-Game prize, your user ID to deliver your prize; and (ii) a physical prize, your contact information to deliver your prize.

 

2. Information about you generated as part of the Game Services

 

We automatically collect certain data from you when you use the Game Services, namely your user ID, country/region, nickname, language, 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, IDFV, XID (if you are a guest user, generated from your existing device information, model, manufacturer, Android ID), WiFi SSID (stored device-side only) and time zone settings), registration time, login time and status, battle and performance information, 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, invite them to team up and share game activities 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 user ID, country and user information, cost, currency, product purchased, purchase history, IP address, details of transactions linked to user ID, and device details such as IDFV, network type, network monitoring data, client exports IP, SDK version, application version, OS version, phone model or type of device, internet connection) and use transaction identifiers to detect fraud;

·        if you request for a refund, we use your transaction ID, delivery status, consumption status, refund recommendation and user account flag to help inform and improve the refund process;

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

·        if you have poor network connection, we collect your routing information to analyse the cause to allow you to play the game;

·        if you qualify for a tournament, we use your user ID to invite you to participate;

·        if you take an in-Game screenshot, we process such data (device-side only) to facilitate your sharing of the screenshot on social network;

·        if you enable our highlights replay function, we use your Game operation records, nickname, profile picture and ranking information to provide highlights replay videos that you can share;

·        if you are a highly-ranked player, your battle replay video may be featured as part of the highlights showcased from time to time in-Game;

·        if you choose to participate in our Beta test, the following information is used to verify your eligibility: your login credentials, user ID, account type, Game level, frequency of use of Game, whether your Game account is bound to a Beta test account, and whether you have cheated in the Game;

·        for users in certain regions, if you participate in a group photo event, we process the photo you upload (processed device-side only), the photo generated (processed device-side only), your user ID and your election to share the photo generated;

·        for users in certain regions, if you create or join clans, share or view picture, text or video content, comments or other posts, create or join custom matches, tag content, follow creators, give or receive gifts or otherwise use or customize the Club features: (i) we process your user ID, avatar, rank, country and region, province, city, language, nickname, friends list, joined clans, game title, custom room game data, eligibility tag, gift records, popularity, game props owned and bookmarked, follows, picture, text and video content, likes, comments or other posts you share publicly in the Club or with other clan members, social media links and creator profile and statistics; (ii), we will process your user ID, social media account nickname and content if you choose to showcase content posted on your social media account in-Game; (iii) our content audit feature will detect if any picture, text and video content you share in the Club or with other clan members contains pornography or other content that violates the Community Guidelines or the End User License Agreement and remove content in such cases; (iv) we will process your user ID, carrier, network type, WiFi status, device model, operating system, operating system version, frame rate, page load time, memory information, exception error and stack, exception log to optimize the performance of the Club functions and provide a better user experience;

·        if you apply to be reviewers of user-generated content, we process your nickname, user profile, user ID and Facebook ID;

·        if you share replay videos with your friends on your Moments page, we process your nickname, avatar and any replay videos generated with game operation records that you share;

·        if you add event schedule information to your system calendar, this is provided device-side only;

·        for users in certain regions, when you are using the Game Services, we collect your daily cumulative gameplay time and your daily rest time to prevent gaming addiction;

·        for users in certain regions, we collect your game data, performance data and user preference information to understand your skill levels and preferences, and provide a better user experience;

·        if you contact our support team or use our Q&A function, we collect information including name (optional), user ID, nickname, country/region, device ID and other device information, login channel ID, application version, SDK version, battery level, WiFi strength, free space on device, IP address, network type, OS version, browser type, Game server, platform, carrier, country code, language, source of ticket, details of ticket, number of visits, social media platform information, ID and nickname (if used to login to the Game), profile picture, birthday (day and month), account status (whether an account is suspended and if so, since when, reason for the suspension and game statistics), email address (optional if in-app/in-Game support), phone number (optional), registration time, VIP level, game duration, historical records, items, currency, penalties, logins, activities, recharge, purchases, in-game friend relationships, game match data  and any question or information that you provide in your communications. You also have the option of providing a photo to illustrate any errors;

·        when you enter specific pages (such as the contact page), when you click on certain features (such as to chat or buttons to submit requests or ratings), when you submit related information (such as ratings) and when you view pages and read messages;   

·        when you are using the Game Services our security feature collects (in addition to the categories of data listed above) device information including OAID, IDFV, Android ID and available memory; and a list of installed APK and running apps;

·        when you are using the Game Services, our security and anti-cheating security features (i) monitor users to identify and observe cheating behaviour; (ii) collect (in addition to the categories of data listed above) user’s in-Game instructions to generate an in-Game behavior video clip of suspected cheating behaviour for our review; (iii) detect if your profile picture is related to the sale of plug-ins or pornographic content and change it to a default profile picture if this is the case; (iv) identify abuse, harassment, the sale of plug-ins or other conduct in violation of our End User License Agreement and restrict your use of the chat functions where you have engaged in any of the foregoing if this is the case as well as, if applicable to your region, improve tools used for this; (v) detect if your signature, nickname, profile photo, free text, chat history or audio self-introduction contains malicious information or other content that violates local laws or the End User License Agreement and to block the content or change it to its default setting and prompt you to change it subsequently, as applicable; (vi) detect if you are using tools to cheat, take screenshots where there is suspected cheating behaviour for our review and restrict your use of the Game if this is the case; (vii) review real-time games of users suspected of cheating; (viii) review in-Game video clip and Game data if we receive a complaint about cheating and (ix) review, analyse and combat cheating;

·        if you are restricted from accessing the Game and/or using the chat function, we process your user ID, reason and duration of suspension to notify you and to enforce suspensions and/or to reduce the duration of suspensions;

·        if you share user-generated maps, we process your creator certification information, user information and map information;

·        if you use in-Club UGC map services (if available in your region), we process map tags, map IDs, creator tags, pins and recommendations to facilitate interaction between creators and players;

·        when you interact with friends, we process your nicknames and interaction information such as time of becoming friends in-Game, number of times you invited each other to form teams, number of times you formed teams with each other, number of times you rescued each other to facilitate friend interactions, to operate and manage team activities and achievement progress, and, if enabled, to send you push notifications about friend interactions;

·        when you use our Ptopia Design Project platform, we process your login information, personal homepage information, application information, cookie information, content information, like and comment information, participation information, voting information and reward information, as applicable;

·        when you use the eSports Website, we process your user ID and chat message to deliver your message to your team members if you chat with them, detect and remove any content that contains pornography or which otherwise violates the End User License Agreement and process your user ID send you notifications about the eSports Website services; and

·        if you participate in Game competitions on the FACEIT service, we will share your user ID and match results with FACEIT to facilitate your use of the service.

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 (chat log data and chat content, both audio and text). We generate a user 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, 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 and process your friends list so you can share Game activities with your friends. We use your combat and team data to prepare season reviews for you and to enable you to share such information with other players if these functions are available in your region. Your Game data and country/region are also used to determine if you qualify for, and to invite you to participate in, a tournament.

4. Beta features.

You may have the opportunity to use “beta” features for a limited period of time. These may be accompanied by a notice or flag indicating that they are in “alpha”, “beta”, “test” mode, or similar. These features are made available to help us test new ideas and improvements for the Game. By agreeing to participate in a beta, you understand that we may process data as part of these features in order to ensure the features can function properly and (once the beta period has concluded) to understand whether it makes sense to modify or rollout those features to the broader community. We may also seek your feedback so that we can understand your experience of the features. We will only process personal data for so long as is necessary for us to fulfil these purposes, and thereafter will take steps to delete or de-identify your personal information (including any feedback you provide).

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 functionalities.

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 Websites) 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, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction). By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions we have listed the minimum relevant age in the table below.

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/Switzerland

16

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

Sri Lanka

18

Thailand

20

Tunisia

18

Türkiye

18

United Arab Emirates

21

United Kingdom

13

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 https://www.pubgmobile.com/datasubject or contact us at dpo@proximabeta.com and we will delete such information.

2.     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, the European Economic Area, Switzerland, Thailand, Indonesia, Brazil or Türkiye (each, a “Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

Personal Information

Use

Legal Basis (only relevant if you are located in a Relevant Jurisdiction)

Game

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

Nickname

We use this information to create your account for the Game in accordance with your request.

Necessary to perform our contract with you to provide the Game.

Hashed Nickname

If your account is determined to breach our End User License Agreement or otherwise is found to be undertaking activity which is illegal, defamatory, damaging to the platform or similar, and your account is consequently suspended, we may publish a hashed version of your nickname on our Website and in the Game (including via in-Game pop-up).

It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game, including notifying other players if a participant has been removed for behavior that violates the End User License Agreement.

Social Connect Information (if you choose to log in via your social media account with these networks):

  • WeChat: user ID, profile photo, alias, gender, region
  • Facebook: name, Facebook ID, profile picture, user token, user ID
  • VKontakte: user ID, nickname, first name, last name, profile picture
  • QQ: user ID, profile picture, alias, gender, region
  • Twitter: user ID, nickname, profile picture, user token
  • Google Play: user ID, nickname, profile picture, user token
  • Game Center: user ID, nickname, profile image
  • LINE: user ID, display name, profile image
  • Sign in with Apple: user ID, nickname, profile picture, user token

We use this information to:

·      create your account for the Game in accordance with your request;

·     disclose in-game photos on WeChat, Facebook, VKontakte, QQ, Twitter, Google Play, Game Center or LINE (as applicable) at your request; and

     provide a Q&A function and manual customer service (on Facebook and LINE).

Necessary to perform our contract with you to provide and support the Game.

Gender (if you elect to provide this information to customise gameplay)

We only receive this information if you voluntarily provide it (other than users who log in via their QQ or WeChat social media account, when gender is also collected – please see above). It is used in order to customise gameplay.

Necessary to perform our contract with you to provide the Game with gender-specific content in accordance with your request.

Gender Information: user ID, nickname, gender (if you elect to provide this information for display as part of your profile)

We use this information to enable you to display gender information as part of your profile if you voluntarily provide your gender for this purpose.

Necessary to perform our contract with you to allow you to display gender information as part of your profile.

Date of Birth (not stored)

We use your date of birth to verify your age if you are a user in certain regions. This is processed device-side only and is not transferred to us.

N/A.

Email address (for verification of parental or guardian consent)

If you are located in certain regions, we may ask you to provide an email address for the purpose of verifying parental or guardian consent to use the Game services if you are under the relevant minimum age.

Necessary to perform our contract with you to provide the Game.

Region Location (manually selected by you)

We use this information to:

·       verify your region location;

·       set up your gameplay on a regional server;

·       provide you with your geographic ranking; and

·       improve gameplay.

Necessary to perform our contract with you to provide the Game.

Friends List (WeChat, Facebook, QQ, VKontakte, Twitter)

If you choose to log-in using a social media service, we import the social media user ID and name of the friends from your social media profile so that you can connect with your friends and share game activities with your friends.

If you choose to log-in through Facebook, and connect with your friends that also have the Game, we import the Facebook nickname and profile picture of those friends.

Necessary to perform our contract with you to provide the Game and connect you with your friends.

Friends List (manually added by you)

We use this information so that you can connect with your friends and share game activities with your friends.

Necessary to perform our contract with you to provide the Game and connect you with your friends.

Telephone number and/or email address and/or associated social media account (if you elect to provide this information to receive game updates or, where applicable to your region, promotions). In relation to your telephone number, this includes your telephone number, country code and SMS content (“SMS Sending Records”)

 

We use this information to send you verification codes or information on our game updates via SMS or email.

Where applicable to your region, we may use your contact information to send you information on game promotions and activities.

To the extent applicable and permissible in the Relevant Jurisdiction(s), it is in our legitimate interest to provide you Game updates and promotions.  

Otherwise, we collect this information with your consent.

Telephone number and email address

We use this information to provide a Q&A function and manual customer service (via email and/or social media or messaging platforms such as WhatsApp, Facebook Messenger, LINE).

Necessary to perform our contract with you to provide and support the Game Services.

Email address (if you elect to provide this information to bind your account with your email address)

 

We only receive this information if you choose to enable login by email address (once verified by way of a verification code sent to you).

Necessary to perform our contract with you to provide the Game using your email address.

Telephone number (if you elect to provide this information to bind your account with your telephone number). This includes SMS Sending Records

 

We only receive this information if you choose to enable login by mobile phone number (once verified by way of a verification code sent to you).

Necessary to perform our contract with you to provide the Game using your phone number.

Two-factor authentication information: telephone number, email address (optional), device ID, device model. This includes SMS Sending Records

 

If you choose to bind your phone number and enable two-factor authentication, we use this information for verification when you log in from a new device.

Necessary to perform our contract with you to enable two-factor authentication.

Telephone number and User ID (if you elect to be featured on leaderboards). In relation to your telephone number, this includes SMS Sending Records

 

We use this information to bind your account with your telephone number and send you SMS verification codes if you would like to be featured on leaderboards.

It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game.

Telephone number (when you provide this information to bind your account with your telephone number to change your location setting in certain regions). In relation to your telephone number, this includes your telephone number and country code

 

We use this information for the purposes of enabling login by mobile phone number if you choose to change your location setting in certain regions.

We collect this information with your consent.

Location information (province and city manually selected by you) and nickname

We use this information if you voluntarily provide this to enable your use of region-specific features, for example our Battle Zone Leaderboard, People Nearby, Regional Chat Channel and birthday features.

Necessary to perform our contract with you to provide region-specific features.

Birthday feature information: user ID, birthday (month and day), location information

We use this information if you choose to display your birthday and location information to other players.

Necessary to perform our contract with you to provide birthday features.

Game-based Event Information (digital prizes): email address and telephone number

If you participate in a game-based event, we use your contact information to send you your prize if you win.

N/A.

Game-based Event Information (physical prizes): name (as shown on passport), email address, telephone number, mailing address and postal code

If you participate in a game-based event, we use your contact information to send you your prize if you win.

Necessary to perform our contract with you to deliver your prize.

Calling Card Information: user ID, profile information, in-game preferences, audio self-introduction, generated QR code (including camera permission and photo album permission) and any other information you share in your calling card

 

We use this information to enable you to display or share this information with other players if these functions are available in your region.

Necessary to perform our contract with you to provide calling card features.

Data Subject Request Information: country/region, name, user email address, screenshot of user ID and user nickname, user ID, account registration date, login method, user nickname of linked social media account, account UC balance, account BP balance, request details, any other information necessary to verify your identity, and if the request is made by a requestor on your behalf, name of requestor, email address of requestor, requestor's relationship with you, proof of your identity and requestor's authority

 

If a data subject request is submitted, we use this information to confirm your and, if applicable, the requestor’s identity, your rights and to process the request.

Necessary to comply with a legal obligation.

Information generated as part of the Game Services

Generated user ID

We generate this and use this to:

  • store your Game data (including level and progress) with your profile;
  • to support your use of the Game and Game activities; and
  • to allow you to delete your account.

Necessary to perform our contract with you to provide and support the Game.

Battle Information: user data (such as channel, user ID, nickname) and game data (such as gameplay mode information, number of kills, movement speed, jump height)

We generate this and use this to enable you to play the Game.

Necessary to perform our contract with you to provide and support the Game.

Game Play Statistics (Level, Score/s), date and time stamps of actions

We use this information to provide you with feedback and information about your gameplay and progress.

Necessary to perform our contract with you to provide the Game.

IP Address

We use this information to:

  • allow you to connect to the Game server; and
  • suggest your country/region when you seek to change your location setting.

Necessary to perform our contract with you to provide the Game.

Device ID, Device Information application version, battery information, WiFi strength, available space, network type, OS version, platform, carrier, country code, series ID, Android ID, OAID, IDFV, device name, device language, screen DPI, system file information, screen size, device resolution, screen direction, brand, manufacturer, device model, device statistics (of cameras, sensors, systems), XID (if you are a guest user, generated from your existing device information, model, manufacturer, Android ID), time zone settings, RAM, ROM and CPU information), GPU version number, baseband information, registration time and login time

We use this information:

  • to confirm the current network type;
  • to provide users with network type display;
  • to display content in the relevant language;
  • to facilitate automatic download of important resources via WIFI;
  • to facilitate account data migration of guest accounts from the Game to its mini version and for security control and analysis;
  • to improve our services, including the functionality of the Game;
  • to provide a Q&A function and customer service;
  • for security and verification purposes;
  • identify and address bugs and assess game function for optimisation; and

·        to combat users registering for multiple accounts.

It is in our legitimate interest to ensure the security of our services, show you content that may be more relevant to you and your interests, manage registrations and improve our services.

Routing Information (if you have poor network connection): IP address, network speed

We use this information to analyse the cause of poor network connection.

Necessary to perform our contract with you to allow you to play the Game.

WiFi SSID (not stored)

We use this information to download the Game in the background. This is processed device-side only and is not transferred to us.

N/A.

Advertising ID and select device information (User ID, Device ID, IP address and engagement data and search terms)

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.

It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.

Chat Data (audio and text, whether inside a battle (e.g. during actual gameplay) or outside a battle (e.g. in the game lobby)) and chat log data

If you enable chat services (audio and/or text) then we will process such data in order to deliver your messages to other users.

Necessary to perform our contract with you to provide the chat services in-Game.

Transaction Records (in-app): payments on Google Play or iOS App Store (user ID, country, currency, cost, product purchased, IP address, details of transactions linked to user ID, and device details including IDFV, network type, network monitoring data, client exports IP, OS version, phone model, device root status, SDK version, application version).

We use this information to facilitate your payment and maintain a record of your transaction history.

Necessary to perform our contract with you to facilitate your payment and provide you with details of your transactions.

Transaction Records (third party other than Google Play or iOS App Store): user information (name, username, email address, Facebook nickname), device information (including user ID, package name, API call status, WiFi, storage and network access permissions, IP address, OS version, type of device, internet connection), transaction details (time and date, cost, product purchased, currency, order ID, subscription information (including subscription ID)) and transaction records (including user ID, time of transaction, country, email, phone number, purchase history and payment card details).

We use this information to facilitate your payment and maintain a record of your transaction history.

Necessary to perform our contract with you to facilitate your payment and provide you with details of your transactions.

Transaction Identifiers: user ID, Android ID, operating system, country, IP address, login channel, information of UC balance change (including date and time stamps of UC balance change, number of transactions during different periods, number of top-ups during different periods).

We use this information in order to detect fraud on the Game Services.

It is in our legitimate interest to ensure the security of transactions within our services.

Refund information: transaction ID, delivery status, consumption status, refund recommendation and user account flag.

We use this information to help inform and improve the refund process if you request a refund.

Necessary to perform our contract with you to facilitate your refund process.

Customer Support Ticket ID & User Communications with Support or Q&A function: Name (optional), User ID, nickname, country/region, device information (such as device ID, free space on device, device model), operating system, login channel ID, application and Game version, SDK version, battery level, WiFi strength, IP address, network type and environment, OS version, browser type, Game server, platform, carrier, country code, language, source of ticket, details of ticket, number of visits, email address (optional if in-app/in-Game support), phone number (optional) , social platform information, ID and nickname (if used to login to the Game), profile picture, birthday (day and month), account status (whether an account is suspended and if so, since when, reason for the suspension and game statistics), registration time, VIP level, game duration, historical records, items, currency, penalties, logins, activities, recharge, purchases, in-game friend relationships, game match data, any question or information that you provide in communications with our support team or Q&A function, and ticket response information (including date, URL, number of responses, priority). You also have the option of providing a photo/screenshot/video recording to illustrate any errors.

We use this information to:

·        improve our services;

·        respond to your communications;

  • provide troubleshooting, such as addressing and remediating technical issues and bugs.

Necessary to perform our contract with you to provide and support the Game Services.

Operation Statistics: A record of contact pages entered, buttons clicked (the Messenger button, the chat button, data entry form buttons, buttons relating to data subject requests and buttons relating to ratings), rating information submitted, page view and message read information.

We use this information to help us understand user behaviour and how to best support users.

It is in our legitimate interest to ensure the security of our services, improve our services and appropriately respond to user communications.

Safety Observation:

  • Security-Related Information: list of hack or cheating software, in-game screen information, device operation system settings, device information including mobile phone brand, model, CPU structure, CPU model, kernel version, resolution, application package of hack software and installation information; IDFV, Android ID and available memory; and a list of installed APK and running apps.
  • Security-Related Information (if you are using the Game on a PC): basic hardware information, operating system information, machine codes for security authentication, user account information, network information, information of files, processes, modules, memory and driver which is related to the game running, user behaviour and status that may be related to plug-in use or sale of plug-ins through profile pictures, image files, memory image and shellcode which is related to the game running, system API calls, method calls, system procedures and related data of active windows, information on in-game modules, game screenshots, external programs attempting to access private data which belongs to process of game application.

We use this information:

  • for security and verification purposes, including to detect and observe cheating behaviours and consider restricting access to the Game (including a particular device);
  • identify and address bugs and assess game function for optimisation;
  • solve game crashes and optimise compatibility of devices with the Game; and
  • to combat users registering for multiple accounts.

If your account is determined to breach our End User License Agreement, we may consider restricting your access to the Game.

It is in our legitimate interest to ensure the security of our services, to maintain a fair gaming environment in the Game and to manage registrations and improve our services.

Illegal Profile Photos: profile pictures from logged in accounts (existing and new users)

We use this information to detect if your profile picture is related to the sale of plug-ins or contains pornographic content (e.g. erotic photos) and change it to a default profile picture if this is the case.

 

It is in our legitimate interest to ensure the security of our services, to maintain a fair gaming environment in the Game and to prevent the sale of plug-ins or the availability of pornographic content on the services.

Reported Chat Data: user ID, nickname, chat time, system language, chat sequence number and chat data

We use this information to identify abuse, harassment, plug-in sales or other uses of chat in violation of our End User License Agreement,  to consider restricting use of chat function in those cases and, if applicable to your region, to improve the tools we use to identify such violations.

For more information, please refer to the Privacy FAQ for this function.

In the case of audio chat, we store the last 30 seconds of the voice chat on your device. In case of a report or complaint, we process such audio chat data on our servers for the abovementioned purposes.

It is in our legitimate interest to ensure the integrity of the Game and protect users from prohibited conduct.

Video Clips of Suspected Cheating Behaviour:

  • Players suspected of cheating: Player name, avatar and video clip of suspected cheating activity (including sound and chats). The user’s in-Game instructions will be used to generate in-Game behaviour video clip, which will be presented to the reviewer in an anonymized form.
  • Reviewers of generated in-Game behaviour video clips of suspected cheating behaviour: Player name and avatar, user ID, the number of generated in-Game behaviour video clips this player has viewed, review statistics and gaming restrictions applied.

We use this information to review and determine whether users suspected of cheating have cheated in the Game.

It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game.

Complaint Verification Information:

  • Players who report suspected cheating and players suspected of cheating: user ID, nickname, region, battle ID, audit category, priority, recording ID, time, platform, channel, recording description, result verification, source, result reporting
  • Players suspected of cheating: user ID, nickname, number of kills, in-Game ranking and points, gaming restriction data (if cheating is found), strategy hit data and in-Game video clip/screenshot

We use this information to:

·       review complaints and determine whether users suspected of cheating have cheated in the Game; and

·       notify players who have filed a report with the outcome of the complaint,

if this feature is available in your region.

It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game.

Malicious Content Information: signatures, nicknames, profile photos, free text, chat histories, email address and audio self-introduction.

We use this information to detect if you are making available malicious information (i.e. information relating to sale of plug-ins, UC tokens, game accounts, information about game power levelling, or pornographic images) via your signature, nickname, profile photo, audio self-introduction, free text or chat history within the Game or detect if your input contains other content that violates local laws or the End User License Agreement and to block content or change it to its default setting and prompt you to change it subsequently, as applicable.

We may contact you via email if we have detected malicious activity involving your account.

It is in our legitimate interest to ensure the security of our services and to ensure all information made available within the Game is legal.

Cheat Tool Detection Information: resource files and parameter data, cheating reports, screenshots of the Game from your perspective (which will contain nicknames and chats of you and your teammates (this information will be obfuscated), number of kills and game scenes from your perspective), number of kills, user ID and nickname

 

We use this information to review and determine whether users have cheated in the Game, for example, if it is apparent you are using a tool to remove grass in violation of the End User License Agreement. If your account is determined to breach our End User License Agreement, we may consider restricting your access to the Game.

It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game.

Cheat Behaviour Detection Information: screen coordinates of your click events

We use this information to detect and determine whether users have cheated in the Game, for example, if it is apparent you are inactive during a battle or assisting the enemy team. If your account is determined to breach our End User License Agreement, we may consider restricting your access to the Game.

It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game.

Real-Time Game Review Information: user ID of players suspected of cheating, user ID and player level of reviewer of suspected cheating behaviour, review results

We use this information to review and determine whether users suspected of cheating have cheated in the Game.

It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game.

Anti-Plug-in Information: user data (such as channel, user ID, nickname), game data (such as gameplay mode information, number of kills,  movement speed, jump height), device information (such as whether the device is jailbroken, whether security components are disabled), replay video (generated from game operation records) and reports

We use this information to review and determine whether users suspected of cheating have cheated in the Game, analyse and combat cheating.

It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game.

Game Player Suspension Information (if applicable): user ID, reason and duration of suspension, country/region, nickname, language, login status

If you are restricted from accessing the Game and/or using the chat function, we use this information to notify you and to enforce suspensions and/or reduce the duration of suspensions.

It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game.

Gameplay Management System Information (if you are in certain regions): daily cumulative gameplay time and daily rest time

 

We use this information to prevent gaming addiction.

N/A.

Security-Related Information when transactions are conducted: whether certain billing security features of the Android SDK (security development kit) are installed on the device, and if so the version information.

We use this information when transactions are conducted on your account in order to detect fraudulent payment activity.

It is in our legitimate interest to ensure the security of transactions within our services.

Survey Information: Country, Age, Gender, Profession, Email, and content of survey responses.

If you agree to participate in a survey conducted by us, we use this information to improve our services.

We collect this information with your consent.

In-Game screenshot information: whether you have taken an in-game screenshot, and if so the in-game screenshot (which will contain any content displayed at the time)

We use this information to facilitate your sharing of any in-game screenshot on social network. The screenshot is processed device-side only and is not transferred to us.

Necessary to perform our contract with you to facilitate sharing of screenshots.

Highlights Replay Information: Game operation records used to generate replay videos, nickname, user ID, profile picture and linked social media service

We use this information to provide highlights replay videos that you can share within the game or on social media if you enable this function.

Necessary to perform our contract with you to provide highlights replay videos that you can share.

Leaderboard Highlights Information: battle replay, nickname, Game server used by player and ranking.       

We use this information to showcase highlights of top players in-Game.    

It is in our legitimate interest to ensure the integrity of high-scoring players is supported by appropriate evidence in-Game.

Beta Test Account Authentication Information: login credentials, user ID, account type, Game level, frequency of use of Game, whether your Game account is bound to a Beta test account and whether you have cheated in the Game.

If you seek to participate in our Beta test, we use this information to verify your eligibility.

Necessary to perform our contract with you to provide the Beta version.

Group Photo Event Information (if you are in certain regions): the photo you upload, the photo generated, your user ID and election to share the photo generated

If you participate in a group photo event, we use this information to generate a group photo for you, to enable you to save or share the photo on social network and, if you are eligible, to provide you with rewards.

Necessary to perform our contract with you to support your participation in a group photo event.

Sweepstakes Participation Information: name (as shown on passport), email address, user ID, phone number, mailing address, postal code and country.

If you participate in a sweepstakes event, which may be conducted in-Game, on our Website or otherwise, we use this information to send you your prize if you win.

We collect this information with your consent.

Club Information (general): User data (user ID, avatar, rank, country and region, language, nickname, game title, clan information (including clan ID, name and role), custom room game data, eligibility tag, gift records, popularity, game props owned and bookmarked, follows), user-generated content (“UGC”) (picture, text, audio and video content, likes, comments and other posts you share publicly in the Club or with other clan members (including custom competition information and clan announcements) or mirrored to a clan page from your Moments page), social media links and creator profile and statistics

We use this information to enable you to create or join clans (including operating and participating in custom competitions and posting clan announcements), share or view picture, text or video content, likes, comments or other posts, tag content, follow creators, give or receive gifts, display your game title, create or join custom matches or otherwise use or customize the Club features if available in your region.

Necessary to perform our contract with you to provide Club services.

Club Information (country and region, province, city, language, friends list)

We use this information to recommend and display content and clans that may be of interest to you.

It is in our legitimate interest to show you content that may be more relevant to you and your interests.

Club Information (UGC maps):

  • Map tags, map IDs of maps played
  • If you are a map creator: map creator tag, map IDs of maps created, map tags, pins and recommendations

We use this information to facilitate interaction between creators and players if this feature is available in your region.

Necessary to perform our contract with you to provide in-Club UGC map services.

Social Media Account Content: Content posted on your social media account, your social media account nickname and user ID

We use this information to enable you to showcase content posted on your social media account in-Game if you choose to bind your social media account for this purpose.

Necessary to perform our contract with you to facilitate your display of your social media account content in-Game.

UGC Information:

  • Players who share content: user ID, nickname, user profile, clan details, language, country and region, picture, text and video content you share publicly in the Club or with other clan members (including social media account content posted in-Game)
  • Players who apply to be reviewers of shared content: nickname, user profile, user ID and Facebook ID

We use this information to detect whether content shared contains pornography or other content that violates local laws, community rules or the End User License Agreement and remove or block content in such cases.

It is in our legitimate interest to ensure the integrity of the Game and protect users from prohibited conduct.

Moments Information: nickname, avatar, replay videos generated with game operation records

We use this information to enable you to share content with your friends on your Moments page. You can also share such content on a clan page.

Necessary to perform our contract with you to facilitate your sharing of content in-Game.

Clan Announcement Information: clan announcement content

We use this information to detect whether clan announcements contains pornography or other content that violates local laws, community rules or the End User License Agreement and remove or block content in such cases.

It is in our legitimate interest to ensure the integrity of the Game and protect users from prohibited conduct.

Schedule Subscription Information: schedule information

We use this information to enable you to add event schedule information to your system calendar and provide calendar reminders. This is processed device-side only and is not transferred to us.

N/A.

Club Feature Performance Information: user ID, carrier, network type, WiFi status, device model, operating system, operating system version, frame rate, page load time, memory information, exception error, exception log and stack

We use this information to optimize the performance of the Club functions and provide a better user experience.

It is in our legitimate interest to improve our Club services.

Tournament Qualification Information: country/region and Game data (prop types, wins, ranking and Game play statistics)

We use this information to determine if you qualify for a tournament.

Necessary to perform our contract with you to provide Game tournaments.

Tournament Invitation Information (free entry): user ID

We use this information to send you in-Game invitations to free-entry tournaments, if you qualify for such tournaments.

Necessary to perform our contract with you to provide Game tournaments.

Tournament Registration Information (if you register for a tournament): name, email address, country/region and user ID

If you elect to participate in a tournament, we use this information for registration and verification.

Necessary to perform our contract with you to support tournament participation.

E-sports Event Registration Information:

  • team name, registration region, team logo, your name, nationality or residency, email address, Discord ID (if applicable) and user ID.
  • if you qualify to attend in person an e-sports event, we will also ask you for your ID or passport information, date of birth, gender, home address, phone number, photo and social media profile.

If you register for an e-sports event, we use this information to create a team for you in the tournament, to organise and broadcast the tournament and to communicate with the team.

We use the ID/passport information of players who qualify to attend in person an e-sports event to verify that you are located within a country in your nominated Game region and to assist with travel arrangements.

We collect this information with your consent.

Tournament Recording Information: user ID, nickname, battle videos, audio and video recordings during matches

We use this information:

  • to validate that you are the correct Game user and to investigate any allegation of cheating; and
  • for use in marketing and promotional materials.

It is in our legitimate interest to ensure a fair competition environment.

It is necessary to perform our contract with you if you are included in marketing and promotional materials.

Tournament Player Suspension Information (if applicable): name, Game nickname (including variations) and day and month of birth

If you are suspended or from participating in tournaments or e-sports events for cheating or otherwise violating tournament or e-sports event rules, we use this information to enforce the suspension.

It is in our legitimate interest to protect the integrity of the Game and ensure fair play at tournaments and e-sports events.

Tournament Suspension Notice Information: nickname, reason for suspension and duration of suspension

If you are suspended from participating in tournaments or e-sports events for cheating or otherwise violating tournament or e-sports event rules, we may publish this information on our Websites or social media channels.

It is in our legitimate interest to protect the integrity of the Game and ensure fair play at tournaments and e-sports events, including notifying other players if a participant has been removed for behavior that violates tournament or e-sports event rules.

FACEIT Information: user ID, match results (including placement, kills, survival time, damage and other match results)

If you participate in Game competitions on the FACEIT service, we will share this information with FACEIT to facilitate your use of the service.

The FACEIT privacy policy available here will apply to the processing of data by FACEIT.

Necessary to perform our contract with you to support competition participation.

Sharing Event Report Information: Game data (prop types, wins, ranking and Game play statistics).

If you participate in a sharing event, we use this information to prepare a report for you.

We collect this information with your consent.

Season Review Information: combat data (such as weapon hit rate, weapon use time, cumulative eliminations, hits data, daily records) and team data (stats on performance with friends such as number of rescues, number of top 10 rankings, winning percentage and number of joint wins, games and rescues)

We use this information to prepare season reviews for you and to enable you to share such information with other players if these functions are available in your region.

Where used to prepare season reviews for you: Necessary to perform our contract with you to provide season review functions.

Where used to prepare season reviews for other players: It is in our legitimate interest provide season review functions to players.

Battle Performance Information: Battle ID, map ID, opening time, player/team user ID, number of kills by player/team, killing flow, killing count, survival time, damage amount, heal amount, current round rank, assist count, old segment level

For the classic game mode, we use this information to improve resource distribution in the battlefield.

It is in our legitimate interest to improve our services.

Battle Matchmaking Information: User ID, country/region, language, in-game friend list, transaction records, communications volume, engagement with the Game (login frequency and online time), number of friends, task completion record, reporting (by other users) and punishment record, Game data (prop types, wins, ranking, level, achievements, and Game play statistics (including Game history and performance)), in-Game purchase history (time and date, cost, product purchased) (if applicable)

We use this information to understand your performance (such as skill levels) and preferences, to provide a better user experience if this feature is available in your region.

It is in our legitimate interest to improve our services.

Offline Team Invitation Information: User ID, in-Game friends list, Facebook name, Facebook ID, Facebook profile picture, whether you log in via Facebook, your Facebook friends list, whether a Messenger friend is also a player of the Game who logs in via Facebook, and if so, such friend’s user ID, Facebook name, Facebook ID and Facebook profile picture

We use this information so that you can invite friends to team up even when they are offline.

Necessary to perform our contract with you to connect you with your friends.

Account Security Alert Information: Email, user ID, suspicious account activity, player confirmation of account security

If you choose to bind your account with your email address, we will send an account security alert to your email address if we detect any suspicious activity.

It is in our legitimate interest to ensure the security of our services and your account.

Account Recovery Information: Social media account information/email address/telephone number linked to your account, device ID, device brand and model, region where you were when you logged in, login time, network connection method, game mode, recharge time, public channel message time and competition registration data (registered/unregistered)

If you need to recover your account, we will use this information to ask you questions to verify your identity.

It is in our legitimate interest to ensure the security of our services and your account.

Captcha Data: browser language, page URL, status of web worker (if any), verification attempts, browser features, user-agent, screen resolution, page and screen dimensions, page referrer, OS, CPU, canvas value, font, property hash, browser resize, WebGL info, GPU, time zone, plugins, color depth, web driver, character set, device and cursor position, load time, time stamp, login cookie, javascript settings, battery status, IP address, storage and DB status, DoNotTrack status, AdBlock status, domain

We use this information to verify that you are a real person, in order to protect the security and integrity of the Game.

It is in our legitimate interest to ensure that access and login attempts for the Game are genuine.

UGC Map Information: user ID, nickname, map mod ID, map name, map description, map, number of times map was favourited, played and adapted, map instructions (placement and game rules)

We use this information to allow you to share user-generated maps and to provide you with player feedback if these functions are available in your region. Other players can play, copy and modify the maps.

Necessary to perform our contract with you to provide UGC map functions.

UGC Map Review Information: user ID, nickname, map mod ID, map name, map description, map, number of times map was favourited, number of times map was played, map scene recording

We use this information to detect whether content shared contains pornography or other content that violates local laws, community rules or the End User License Agreement and remove or block content in such cases.

It is in our legitimate interest to ensure the integrity of the Game and protect users from prohibited conduct.

UGC Map Creator Certification Information: social media account profile (social media account ID, number of followers of social media account, social media homepage link), questionnaire responses, email address or Discord ID

We use this information to conduct creator certification and to manage creators if these functions are available in your region.

Necessary to perform our contract with you to provide UGC map functions.

Friend Interaction Information: nicknames and interaction information such as time of becoming friends in-Game, number of times you invited each other to form teams, number of times you formed teams with each other, number of times you rescued each other

We use this information to facilitate friend interactions and to operate and manage team activities and achievement progress.

Necessary to perform our contract with you to connect you with your friends.

Friend Interaction Push Notification Information: nickname and friend interactions

We use this information to send you push notifications about friend interactions.

We collect this information with your consent.

Ptopia Design Project (“PDP”) Information: login information (user ID, status token, username, profile picture, initial login channel ID, channel information), personal homepage information (user ID, nickname, avatar, title of work(s), update time of work(s), number of thumbs up, number of comments, number of views, number of events participated), application information (user ID, nickname, email address, telephone number (optional), type of work(s)), cookie information (language, client type, source, area ID), content information (user ID, profile picture, nickname, content of work(s), title of work(s), cover art, type of work(s), description of work(s)), like and comment information (nickname, profile picture, content and time), participation information (list of events participated, name and time of event), voting information and reward information

We use this information to enable you to view or participate in activities on the PDP platform.

Necessary to perform our contract with you to provide PDP services.

PDP Moderation Information: user ID, nickname, profile picture, content of work(s), title of work(s), cover art, description of work(s), comments

We use this information to detect whether content shared or comments posted contain pornography or other content that violates local laws, community rules or the End User License Agreement and remove or block content in such cases.

It is in our legitimate interest to ensure the integrity of the Game and protect users from prohibited conduct.

eSports Website

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

Social Connect Information (if you choose to log in via your social media account with these networks):

  • Sign in with Apple: user ID, nickname, profile picture, user token
  • Facebook: user ID, name, Facebook ID, profile picture, user token
  • Google Play: user ID, nickname, profile picture, user token
  • Twitter: user ID, nickname, profile picture, user token

We use this information to enable you to log in to your account for, and access, the Game Services.

Necessary to perform our contract with you to provide the Game Services.

Email Login Information: email address, user ID

 

We use this information to enable you to log in to your account for, and access, the Game Services by email address (once verified by way of a verification code sent to you).

Necessary to perform our contract with you to provide the Game Services.

User Registration Information: name, region location (as selected by you), area ID, email address

 

We use this information to enable you to register as a player on the eSports Website and to participate in eSports events. We will send you a verification code to verify your email address.

Necessary to perform our contract with you to provide the Game Services.

Account Binding Information: user ID, profile picture, nickname, ranking information

We use this information to bind your Game account as part of player registration on the eSports Website.

Necessary to perform our contract with you to provide the Game Services.

Team Information: user ID, profile picture, nickname, ranking information, team name, Discord username (for captain only), region, team slogan, team role (captain or member)

We use this information to enable you to form, view or join teams and to participate in eSports events.

Necessary to perform our contract with you to provide the Game Services.

eSports Website Event Registration Information: profile picture, nickname, ranking information, team rank, gameplay statistics

We use this information to enable you to participate in eSports events.

Necessary to perform our contract with you to provide the Game Services.

Customer Support Ticket ID & User Communications with Support: email address and any information that you provide in communications with our support team

We use this information to:

·        respond to your communications;

·        provide troubleshooting, such as addressing and remediating technical issues and bugs; and

·        improve our services.

Necessary to perform our contract with you to provide and support the Game Services.

Information generated as part of the Game Services

Chat Data: user ID, chat message (stored locally on your device and processed momentarily by our servers)

We facilitate your chat communications with your team members.

Necessary to perform our contract with you to provide the Game Services where you seek to use chat services.

Notification Information: user ID

We use this information to send you notifications about announcements, updates or information relating to the eSports Website services.

Necessary to perform our contract with you to provide the Game Services.

Website Events (if available in your region)

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

Social Connect Information (if you choose to log in via your social media account with these networks):

  • Facebook: user ID, Facebook ID, name, profile picture, user token
  • Twitter: user ID, nickname, profile picture, user token
  • YouTube: user ID, nickname, profile picture, user token
  • Discord: user ID, nickname, profile picture, user token

We use this information to enable you to create and log in to your account for the Website event services.

Necessary to perform our contract with you to provide the Website event services.

Email Login Information: user ID, email address

 

We use this information to enable you to create and log in to your account for the Website event services by email address (once verified by way of a verification code sent to you).

Necessary to perform our contract with you to provide the Website event services.

Event Registration Information: user ID, in-Game screenshot with user ID, 

Discord ID, region location (manually selected by you), telephone number

We use this information to enable you to register for a Website event.

Discord ID and telephone number are used to provide information about the Website event as well as Q&A and customer services (on Discord and if applicable, WhatsApp).

In-Game screenshot with Game player ID is also used to detect if you are making available malicious information within the Game Services. For more information, please refer to “Malicious Content Information” above for this function.

Necessary to perform our contract with you to provide the Website event services.

Lucky Draw Winner Information: hashed nickname

If you participate in a Website event and win, we use this information to announce your win.

It is in our legitimate interest to announce lucky draw results.

Prize Delivery Information (Physical Prize): name, telephone number, address with zip code

If you win a physical prize at a Website event, we use this information to deliver your prize.

Necessary to perform our contract with you to deliver your prize.

Prize Delivery Information (In-Game Prize): user ID

If you win an in-Game prize at a Website event, we use this information to deliver your prize.

Necessary to perform our contract with you to deliver your prize.

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.

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, Indonesia and the United States. 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:

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

·        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 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 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 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) and for the purpose of informing and improving the refund process if you request a refund. 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.

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).

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

 

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

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 (province and city manually selected by you) and nickname 

Birthday feature 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 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.

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) – outside a battle (e.g. in game lobby)

Stored for 7 days on our servers and deleted automatically upon expiry of such period.

Chat Communications (Audio message) – inside a battle (e.g. during actual gameplay)

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

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.

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)

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.

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).

Operation Statistics

Stored for 90 days. Upon a deletion request, we will delete the data within 30 days.

Security-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.

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 7 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

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.

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: (a) if you provide your email as part of the survey, up to 6 months (in order for us to follow up with you) and then the data is anonymised; or (b) if you do not provide your email as part of the survey, up to 1 month and then the data is anonymised.

In-Game screenshot information

Not stored. This is processed device-side only and is not transferred to us.

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.

Social Media Account Content

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 and video content you share any time.

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.

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.

Schedule Subscription Information

Not stored. This is processed device-side only and is not transferred to us.

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 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 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, for providing game promotion emails where applicable to your region, and for providing manual customer service

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

Account Recovery 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

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.

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.

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.

 Website Events

Social Connect Information

Email Login Information

Event Registration Information

Lucky Draw Winner Information

Prize Delivery Information (Physical Prize)

Prize Delivery Information (In-Game Prize)

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 https://www.pubgmobile.com/datasubject.

Access

You have the right to access personal information we hold about you, how we use it, and who we disclose it to. 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 https://www.pubgmobile.com/datasubject.

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 account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at https://www.pubgmobile.com/datasubject

Erasure

You can delete your account, or remove certain personal information, by logging into your account. If there is any other personal information you believe we process that you would like us to erase, please contact us at https://www.pubgmobile.com/datasubject.

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 https://www.pubgmobile.com/datasubject.

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 https://www.pubgmobile.com/datasubject. 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. 

7.     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 region in which you live or work where you consider we have infringed data protection laws.

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 and the United States of America (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 at dpo@proximabeta.com.

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 at dpo@proximabeta.com.

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 and the United States.

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 https://www.pubgmobile.com/datasubject. 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.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”). For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the CCPA and do not include information excluded from the CCPA’s scope.

 

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:

 

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

 

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 to the following types of entities:

 

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. 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 the CCPA

 

If you are a California resident and the CCPA does not recognize an exception that applies to you or your personal information, you have the right to:

 

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 also exercise your rights, if any, regarding other data by contacting us at https://www.pubgmobile.com/datasubject. 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”.  

 

Under the CCPA, 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.

 

Questions

 

If you have questions or concerns regarding this Privacy Policy, please contact us at dpo@proximabeta.com.

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, you 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.

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, Indonesia, the People’s Republic of China and the United States.

 

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 at dpo@proximabeta.com.

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 https://www.pubgmobile.com/datasubject. 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, Indonesia and the United States.

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

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 this privacy policy.

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.

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 at dpo@proximabeta.com.

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 at dpo@proximabeta.com.

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, email: dpo@proximabeta.com.

·       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

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 at dpo@proximabeta.com.

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 dpo@proximabeta.com.

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

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.

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

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.

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:

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:

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 dpo@proximabeta.com. 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 (dpo@proximabeta.com): 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.

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, Indonesia, the People’s Republic of China and the United States.

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 https://www.pubgmobile.com/datasubject.

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 https://www.pubgmobile.com/datasubject.

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

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 https://www.pubgmobile.com/datasubject.

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):

 

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

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

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

Reported chat data

GameStars Inc.

United States

Provide online platform for eSports events

eSports Website Event Registration 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.

Virginia

This section applies to Virginia residents covered by the Virginia Consumer Data Protection Act (“VCDPA”). For purposes of this section, “personal data” and “sensitive personal data” have the meanings given in the VCDPA and do not include information excluded from the VCDPA’s scope.

If you are a Virginia resident and the law does not recognize an exception that applies to you or your personal data, you have the right to:

 

We do not collect sensitive personal data about you. We also do not process personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

How to Exercise Your Rights

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

How to Appeal Decision on Your Request

If you would like to appeal a decision on your request to exercise any right you have under the VCDPA, you may contact us at dpo@proximabeta.com.


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 via email at dpo@proximabeta.com 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 in anonymized form for improvement of the tools we use to identify violations, on our servers in the United States and 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 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 dpo@proximabeta.com 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.