Alchemy Stars

Privacy Policy

Last Updated: 17 June 2021

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 (“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?

If you register an account to participate in the Game then we will need some information from you such as your email or social media account details (Apple, Google, Facebook, Twitter or LINE) to set this up. We also collect other information, including your IP address and device and log information to personalise the gaming experience and enable Game features. If you choose to participate in a survey regarding the Game, we will redirect you to our affiliate platform to take the survey and will receive your survey data from that affiliate once you complete the survey. More Information.

How will we use your information?

We use your information to provide the many functions and services that comprise the Game. We also use your information for account verification and analytics purposes to support and improve the Game. We do not share your information with any third parties, except where we need to in order to provide the Game (e.g., for the purposes of analytics and user acquisition, or to allow you to participate in a survey regarding the Game), or where we are instructed to by a court, authority or compelled by law. More Information.

Who do we share your information with?

We use some third parties for analytics and user acquisition purposes. 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 surveys in relation to the Game, 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 Germany, Japan, Korea and Singapore. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore. 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 the 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 are, 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 Privacy Policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. More Information.

Contact Information

Data Controller: Proxima Beta Pte. Limited | Email: dpo_alchemystars@proximabeta.com    

 


Welcome to the Alchemy Stars!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the mobile game Alchemy Stars (the “Game”), 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. By using the Game, you are acknowledging 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  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_alchemystars@proximabeta.com.

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

Jurisdiction

Representative

Address

Contact details

EU

Proxima Beta Europe B.V.

Gustav Mahlerplein 2, 1082 MA,  Amsterdam, the Netherlands

dpo_alchemystars@proximabeta.com 

Korea

Tencent Korea Yuhan Hoesa

 

152, Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Korea

dpo_alchemystars@proximabeta.com  

Serbia

Karanovic & Partners o.a.d. Beograd

Resavska 23, Belgrade, 11000, Serbia

local.representative@karanovicpartners.com

Turkey

Özdağıstanli Ekici Avukatlık Ortaklığı.

Varyap Meridian Grand Tower ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul Turkey

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_alchemystars@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 Information” below. 

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

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

 

· Guest log in information: A new OpenID will be generated every time you log into the Game as a “guest”

· Account registration information (direct via email): When you set up an account to register for the Game via email, we will collect your email address, email verification code, password, client IP and OpenID

· Account registration information (via social media accounts): When you choose to log into the Game with your social media account (Apple, Google, Facebook, Twitter or LINE), we import information from your connected social media account in order to set up your profile. This will include your name as it appears on your social media profile, nickname, user ID/Facebook ID/Apple ID/token, OpenID and profile picture (if any)

· Survey information: If you choose to participate in a survey about Alchemy Stars, you may be asked to provide certain personal information, such as your age, gender, email, address, geographic (country) location, game information (game habits and preferences) and any other content you choose to provide as part of the survey response. We will use your survey response for the purpose of improving the Game

· Customer service (Game data): When you choose to use our Customer Service, we will collect information such as your OpenID, Game ID, OS, area ID, role ID, Game server ID, zone ID, customer name, character ID

 

· Customer service (chat data)

 

· Customer service (users’ software and hardware data, agents custom data)

 

b) Information about you generated as part of the Game

 

We automatically collect certain data from you when you use the Game, namely:

 

· Game data (including log information and gameplay statistics): Your OpenID, RoleID, Game account, user nickname, country code, device system version, device brand, IDFV, device model, device manufacturer, device name, screen resolution, screen orientation, CPU model, GPU information, RAM, client exports IP, phone memory, login channel ID, operator name, network type, signal strength, and buried data reporting, and gameplay statistics (player level, in-game performance, purchased items, virtual currency)

 

· Survey data: User ID, Open ID, IP address, browser version, device settings and operating system version: in order to allow the survey to be completed within the Game and to optimise the Game

 

· IP address

· For the purposes of announcements and in-game notifications: Your OpenID and device information (guest ID, device language, device version, brand, APP version, screen size, network type, ROM, RAM and CPU name)

· Analytics (Firebase): OpenID, Information uploaded to be determined by product team (including number of users and sessions, session duration, operating systems, device models, geography, first launches, app opens, app updates, in-app purchases)

· For the purposes of user acquisition via third-party SDKs (Facebook and Appsflyer): Technical Information, technical identifiers and engagement information

· For data analytics purposes: IP address, country and certain device information

· Chat data: OpenID and free text. Minors can communicate only through a limited chat function of pre-set text messages (quick chat)

· Security (profanity filter): SDK log data, server IP, OpenID, system information (system version, brand, CPU architecture, system boot time, country code and language), root status, whether it is running in the simulator, APK information, running process information, file name list under SD card application cache directory, application package name, process name, application version, start-up time, host file, in-game screen, device information (including device type, IDFV, network type, brand, language region, RAM space size, ROM space size), jailbreak status (iOS), whether there is any external file (plug-ins)

· Compliance features: OpenID, token, region, username and email address

· In-app purchases: OpenID, country, role ID, relevant information regarding your device (CPU model, device brand, device system version, client exports IP, ROM, RAM, CPU architecture, remaining external SD card space, remaining memory, device manufacturer, screen orientation, screen resolution, device model) and other information (country currency, SDK version, login channel ID, application version, buried data reporting, IDFA (identifier for advertisers), network type, IP address, network monitoring data, application package name, IDFV (identifier for vendor) and user purchase transaction record (including user ID, purchase quantity, purchase amount and transaction time)

Children

Children must not use the Game for any purpose, except where their parent or guardian has provided consent.

By children, we mean users under the age of 18 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries we have listed the relevant minimum age in the table below.

Country in which the user is located

Minimum age of the user

Algeria

19

Argentina

18

Australia

18

Bangladesh

18

Brazil

18

Cambodia

18

Canada

13

Colombia

18

Egypt

18

European Economic Area/United Kingdom/Switzerland

16

Indonesia

21

Japan

20

Kingdom of Saudi Arabia

15

Kuwait

21

Malaysia

18

Mexico

18

Morocco

18

Myanmar

18

New Zealand

16

Philippines

18

Qatar

18

Republic of Korea

14

Russia

14

Singapore

18

South Africa

18

Sri Lanka

18

Thailand

20

Tunisia

18

Turkey

18

United Arab Emirates

21


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/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo_alchemystars@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 or Turkey (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

Personal Information

Use

Legal Basis

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

Guest log in information: OpenID

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

Account registration information (direct via email): Email address, email verification code, password, client IP and OpenID

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

Account registration information (via social media accounts) (if you choose to log in via your social media account with these networks):

· Apple: Apple ID, nickname, profile picture, user token and OpenID

· Google: UserID, nickname, profile picture, user token and OpenID

· Facebook: Facebook ID, name, profile picture, user token and OpenID

· Twitter: UserID, nickname, profile picture, user token and OpenID

· LINE: UserID, nickname, profile picture, user token and OpenID

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

Survey information: age, gender, email, address, geographic (country) location, game information (game habits and preferences, e.g. recently played games, game duration and favourite game categories and experience, social media preference, language preference) and any other content you choose to provide as part of the survey response

We use this information to better understand our users and to improve the Game

We collect this information with your consent

Customer service (Game data): OpenID, Game ID, Operating System, area ID, role ID, game server ID, zone ID, player name, character ID, level of character, player's VIP level, player's remaining balance, account status, name of the game, account binding status, registration time, latest login time, player type

We use this information to:

· improve the Game, including the functionality of the Game

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

Necessary to perform our contract with you to resolve customer service issues and support the Game

Customer service (chat data): chat data collected from:

· Robotic sessions: number of bot sessions served (person), number of bot resolutions (tickets), number of bot-to-man sessions (tickets), number of customer collection sessions (tickets), number of customer collection interruptions (tickets), number of unrecognized sessions (tickets), average number of interactions

· Manual sessions: number of person sessions (tickets), number of person sessions (person), number of processed sessions (tickets), number of unprocessed sessions (tickets), number of sessions automatically closed after timeout (tickets), number of users who repeatedly raised orders twice (person), number of rejected orders (tickets), number of work orders created (tickets), number of transferred sessions (tickets), average length of first response, average length of response timeout sessions, average length of processing (hours), number of sessions processed per person (tickets/day)

· Chat history: customer chat history (content in written form)

 

Customer information collection: email address, customized information

We use this information to get a clearer picture of your customer service experience

Necessary to perform our contract with you to resolve customer service issues and support the Game

Customer service (users’ software and hardware data, agents custom data): channel ID, application identifier, application version, application name, OS version, platform, country code, language, SDK version, carrier, network type, device model, battery level, battery status, total space phone, free space phone, capacity, VIP level, diamonds number, GLOD number, pet number, unlocked level

We use this information to help you solve technical issues in accordance with your request

Necessary to perform our contract with you to resolve customer service issues and support the Game

Information generated as part of the Game

Game data: OpenID

We use this information to identify you in Game logs and to allow you to connect to the Game

Legitimate interest to identify user logs, store Game data (including level and progress) with user's profile and allow the user to connect to the server

Survey data: User ID and Open ID

IP address, browser version, device settings and operating system version

We use this information to allow you to complete the survey (if you wish to participate) in-app and to optimise the Game

We collect this information with your consent

Game data: IP address

We use this information to allow you to connect to the Game

Necessary for the performance of the contract, as it allows the user to connect to the game server

Game data (log information and gameplay statistics): RoleID, Game account, user nickname, country code, device system version, device brand, IDFV, device model, device manufacturer, device name, screen resolution, screen orientation, CPU model, GPU information, RAM, client exports IP, phone memory, login channel ID, operator name, network type, signal strength, buried data reporting and gameplay statistics (player level, in-game performance, purchased items and virtual currency)

We use this information:

· to improve the Game, including the functionality of the Game

· to maintain a record of log-in and actions of your account

· for security and verification purposes

· to provide you with feedback and information about your gameplay and progress

Necessary for the performance of the contract, as game data allows users to play the game and for details of their use to be documented and saved for future gameplay

Announcements and in-game notifications: Your OpenID and device information (guest ID, device language, device version, brand, APP version, screen size, network type, ROM, RAM and CPU name)

We use this information to notify you of the latest news of Alchemy Stars

Necessary for the performance of the contract, to notify you of the latest news of Alchemy Stars

Analytics (Firebase): OpenID, Information uploaded to be determined by product team (including number of users and sessions, session duration, operating systems, device models, geography, first launches, app opens, app updates, in-app purchases)

We use this information for data analytics purposes to provide you with a better gaming experience  

Legitimate interest to improve the game and provide you with a better gaming experience  

User acquisition data via third-party SDKs (Facebook and Appsflyer):

Technical Information: Browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier

Technical Identifiers: User agent, IDFA (identifier for advertisers; only processed for the purpose of serving advertisements), Google Advertiser ID and your OpenID

Engagement Information: Clicks on ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, the webpages website visited, the URL from the referring website, downloads and installations of applications and other interactions

Contact Information: name, email address, and phone numbers, that are used for matching purposes only

Event Data: information shared by the user about people and the actions that they take on our websites, apps or shops, such as visits to our sites, installations and purchases of our products. Event Data includes information collected and transferred when people access a website or app with Facebook Login or Social Plugins (e.g. the Like button)

We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements via analytics

Legitimate interest to allow us to acquire users and to monitor the effectiveness of our advertisements

 

Data analytics:

Country, IP address

Device information: application version, application ID, battery information, WiFi strength, available space, network type,

OS version, OS name, carrier, country code, Google Advertising ID, IDFV, device language, device resolution, brand, manufacturer, device model, RAM, ROM and CPU information, GPU information, Game Frame information, mobile signal strength, network round trip time, network bytes received/sent

We use this information for analytics purposes to provide you with a better gaming experience

 

Legitimate interest to provide you with a better gaming experience

 

Chat Data: Open ID

Free Text Chat: users can communicate using their own, custom messages

Quick Chat: minors can communicate only through a limited chat function of pre-set text messages

We facilitate the posting of your communications with other users

Open ID: Contract

Free Text Chat and Quick Chat:

· Online chat data is only stored on your device, and is not processed by us

· We will only temporarily store offline chat data until the message is received by the message recipient after which it is automatically deleted from our server. Storing offline chat data is necessary for the performance of our contract to allow offline users to receive chat messages once they come online

 

Security (profanity filter): SDK log data, server IP, OpenID, system information (system version,  brand, CPU architecture, system boot time, country code and language), root status, whether it is running in the simulator, APK information, running process information, file name list under SD card application cache directory, application package name, process name, application version, start-up time, host file, in-game screen, device information (including device type, IDFV (identifier for vendors) and, network type, brand, language region, RAM space size, ROM space size), whether user may escape from prison, whether external file has detection

We use this information for security purposes in order to detect offensive and sensitive wording to provide a fair and secure gaming environment and to combat users registering for multiple accounts on the same device

 

Legitimate interest provide a fair and secure Game and to combat users registering for multiple accounts on the same device

Compliance features: OpenID, token, region, username and email address

We use this information for compliance purposes in order to verify your age, verify your parent’s or legal guardian’s consent

Necessary to perform our contract with you to allow you to use the Game

In-app purchases: OpenID, country, role ID, relevant information regarding your device (CPU model, device brand, device system version, client exports IP, ROM, RAM, CPU architecture, remaining external SD card space, remaining memory, device manufacturer, screen orientation, screen resolution, device model) and other information (country currency, SDK version, login channel ID, application version, buried data reporting, IDFA (identifier for advertisers), network type, IP address, network monitoring data, application package name, IDFV (identifier for vendors) and user purchase transaction record (including user ID, purchase quantity, purchase amount and transaction time)

We use this information in order to process any payments you make within the Game

Necessary to perform our contract with you to provide the Game, information about your purchase history and to restore purchases items

We collect the IDFA with your consent

 

3. How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to allow you to participate in the Game, your personal information will be processed on servers that may not be located where you live. 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 are located in Germany, Singapore, Korea and Japan.

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore.

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

· Third parties that provide services in support of the Game, including providers of user acquisition and analytics services that process information identified in this Privacy Policy on their servers for the purposes of assisting us with acquiring users for the Game and analytics purposes to improve your gameplay. 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.

· Companies within our corporate group who process your personal information in order to operate the Game and conduct surveys for us. All related group companies may only use your personal information in accordance with this Privacy Policy.

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

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

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

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

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

4. The Security of Your Personal Information

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

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

5. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information

Retention Policy

Guest log in information: OpenID

Stored for the lifetime of your use of the Game unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Where you do not request for account deletion, your data will be retained for 1 year after the Game is shut down, before it is deleted.

Account registration information (email): Email address, email verification code, password, client IP and OpenID

Stored for the lifetime of your use of the Game unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Where you do not request for account deletion, your data will be retained for 1 year after the Game is shut down, before it is deleted.

Account registration information (social media information) (if you choose to log in via your social media account with these networks):

· Apple: Apple ID, nickname, profile picture, user token and OpenID

· Google: UserID, nickname, profile picture, user token and OpenID

· Facebook: Facebook ID, name, profile picture, user token and OpenID

· Twitter: UserID, nickname, profile picture, user token and OpenID

· LINE: UserID, nickname, profile picture, user token and OpenID

Stored for the lifetime of your use of the Game unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Where you do not request for account deletion, your data will be retained for 1 year after the Game is shut down, before it is deleted.

Customer service (Game data)

 

Stored for the lifetime of your use of the Game unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Where you do not request for account deletion, your data will be retained for 1 year after the Game is shut down, before it is deleted.

Customer service (chat data)

 

Customer service (users’ software and hardware data, agents custom data)

 

Stored for the lifetime of your use of the Game unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Where you do not request for account deletion, your data will be retained for 1 year after the Game is shut down, before it is deleted.

Game data: OpenID, IP address, log information and gameplay statistics

IP address

Stored for the lifetime of your use of the Game unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Where you do not request for account deletion, your data will be retained for 1 year after the Game is shut down, before it is deleted.

Survey data: User ID and OpenID

IP address, browser version, device settings and operating system version

Automatically deleted after one year of collection unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Survey information

Automatically deleted after one year of collection unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Announcements and in-Game notifications

Stored for the lifetime of your use of the Game unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Where you do not request for account deletion, your data will be retained for 1 year after the Game is shut down, before it is deleted.

Analytics (Firebase)

Automatically deleted after 180 days of collection unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

User acquisition data via third-party SDKs (Facebook and Appsflyer) 

Automatically deleted after 180 days of collection unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Data analytics

Automatically deleted after 30 days of collection.

Chat data (OpenID)

OpenID: Manually deleted after one year of collection unless you contact our customer service team and request to delete such data, in which case, the data will be deleted within 7 working days upon your request.

Free Text Chat and Quick Chat:

· Online chat data is only stored on your device, and is not processed by us

· We will only temporarily store offline chat data until the message is received by the message recipient after which it is automatically deleted from our server

Security (profanity filter) data

Stored for 90 days unless you request to delete your Game account, in which case your data will be deleted within 30 days of your request, with the exception of malicious files.

Compliance features

Stored for the lifetime of your use of the Game unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Where you do not request for account deletion, your data will be retained for 1 year after the Game is shut down, before it is deleted.

In-app purchases

 

Stored for the lifetime of your use of the Game unless you request to delete your Game account or such data, in which case, the data will be deleted within 30 days upon your request.

Where you do not request for account deletion, your data will be retained for 1 year after the Game is shut down, before it is deleted.

 

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. 

If you request to delete your data, we will delete your data within 30 days of your request.

6. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Game, 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, Argentina and Russia.

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 contact us at dpo_alchemystars@proximabeta.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us at dpo_alchemystars@proximabeta.com.

Portability

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

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo_alchemystars@proximabeta.com

Erasure

You can delete your account, or remove certain personal information. If there is any personal information you believe we process that you would like us to erase, please contact us at dpo_alchemystars@proximabeta.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Restriction of Processing to Storage Only

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

Objection

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

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

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 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 

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo_alchemystars@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_alchemystars@proximabeta.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

8. Changes

If we make any material changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

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 TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Game, 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, 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 (local cloud providers to back up your data or our affiliates around the world to help us deliver the Game) located in Germany, Japan, Korea and Singapore (as described in the Privacy Policy) where it is manually and electronically treated.

Argentina

Your rights

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

Data transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing us your personal information and by using the Game, 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. If you believe we hold any other personal information about you, please contact us at dpo_alchemystars@proximabeta.com.

Correction

 

You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo_alchemystars@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.

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. 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.

 

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 “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Germany, Japan, Korea and Singapore.

Age Restriction

In order to use the Game, 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 dpo_alchemystars@proximabeta.com. This may affect our provision of the Game to you.

 

Parental and Guardian Consent

 

If you are under the age of 18, you should not use the Game 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 AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

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_alchemystars@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. Queries will be attended to within a maximum term of ten (10) business days from the date of receipt. When it is not possible to attend the query within the said term, you will be informed of the reasons for the delay and we will indicate the date on which the consultation will be attended to, which may, in no case, exceed five (5) business days following the expiration of the first term.

 

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. The term to attend to the claim will be fifteen (15) business days from the date of receipt. When it is not possible to attend to the claim within the said term, you will be informed of the reasons for the delay and the date on which the claim will be handled, which may, in no case, exceed eight (8) business days following the expiration of the first term.

Egypt

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

 

By clicking “accept” 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.

 

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.

 

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_alchemystars@proximabeta.com.

Indonesia

Consent

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

Parental and Guardian Consent

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

Data Subject Rights

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

Data Breach

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

Data Retention

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

Notification to Amendment of this Privacy Policy

If you fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen (14) days of the date the relevant amended version of this Privacy Policy is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy. However, you may stop using or accessing the Game by unsubscribing or ceasing your use of the Game at any time, if you cease to agree with the amended Privacy Policy.

Data Accuracy and Third Party Consent

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

Japan

Minimum Age

If you are under the age of 20, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Game.

Consent to transfer to third parties

By clicking “accept”, you consent to 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.  

 

Your Rights

 

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at dpo_alchemystars@proximabeta.com.

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, export 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.

Malaysia

Parental and Guardian Consent

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

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Game, 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 requester to ensure that he/she is the person legally entitled to make the data access request.

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

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

Contact

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

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

o Telephone: +603-22872388

o Email: dpo_alchemystars@proximabeta.com 

Mexico

Age Restrictions

You won’t be able to use the Game 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 1 "The types of personal information we use” and section 2 “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. You may object 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 to carry out the transfer of personal data detailed in section 3 “How we store and share your personal information”.

Data Transfer Consent

In general, we do not require your consent to carry out the transfers detailed in section 3 “How we store and share 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 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 includes the limitation to the use and disclosure of your personal data 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_alchemystars@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_alchemystars@proximabeta.com.

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.

 

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

 

Kindly note:

 

· the identity of the Data Controller is Proxima Beta Pte. Limited, email: dpo_alchemystars@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 Share 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. If you believe we hold any other personal information about you, please contact us at dpo_alchemystars@proximabeta.com.

Correction

You have the right to request the correction of any of your personal information we hold that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo_alchemystars@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.

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

Transfers and delegation of personal information occur as set out in this Privacy Policy and the section “Republic of Korea”.

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.

· Data Protection Team, responsible for the management and safety of your personal information

· Contact: dpo_alchemystars@proximabeta.com

Philippines

Minimum Age

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

Your Rights

You are entitled to the following rights:

· Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.

· Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.

· Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.

· Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.

· Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

Consent

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

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

· sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially 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 Share Your Personal Information” above.

Qatar

If you are using the Game 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.

Republic of Korea

How We Store and Share Your Personal Information

Delegation of Processing

For the performance of the services detailed in this Privacy Policy, we delegate the processing of your personal information to the following professional service providers:

We provide your personal information to third parties as described below:

Name of Recipient (and contact information)

Types of Personal Information provided

Purpose of Use by Recipient

Period of Retention and Use by Recipient

Appsflyer

(https://www.appsflyer.com/services-privacy-policy/)

(United States unless otherwise described in the service provider’s  privacy policy)

Technical information, technical identifiers, engagement information,

User acquisition purposes and to monitor the effectiveness of our advertisements

In accordance with the Appsflyer privacy policy

Facebook Analytics

(https://www.facebook.com/policy.php)

(United States unless otherwise described in the service provider’s  privacy policy)

Technical information, technical identifiers, engagement information, contact information, event data

User acquisition purposes and to monitor the effectiveness of our advertisements

In accordance with the Facebook Platform Terms for Developers and privacy policy

Google Analytics (Firebase)

(https://policies.google.com/privacy)

(United States unless otherwise described in the service provider’s  privacy policy)

Technical information, technical identifiers, engagement information, contact information, event data

Data analytics

In accordance with the Google Developer License Agreement and privacy policy

 

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

Recipient (Contact Information of Information Manager)

Country to which Your Personal Information is to be Transferred

Date and Method of Transfer

Types of Your Personal Information to be Transferred

 

Purposes of Use by Recipients

Period of Retention of Use by Recipient

Appsflyer

United States unless otherwise described in the service provider’s privacy policy

Transmitted from time to time

Analytics data (Appsflyer SDK)

User acquisition

In accordance with Appsflyer’s Privacy Policy  (https://www.appsflyer.com/services-privacy-policy/)

Facebook (Analytics)

United States unless otherwise described in the service provider’s privacy policy

Transmitted from time to time

Analytics data (Facebook SDK)

User acquisition

In accordance with Facebook’s Privacy Policy  (https://www.facebook.com/policy.php)

Google Analytics (Firebase)

United States unless otherwise described in the service provider’s privacy policy

Transmitted from time to time

Analytics data

Data analytics

In accordance with Firebase’s Privacy Policy  (https://firebase.google.com/support/privacy)

 

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed in section 4 “Data Retention”. With the exception of the personal information set out below, personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

The personal information is required to be retained beyond the data retention periods as detailed in section 4 “Data Retention” are required to be retained pursuant to the following laws:

 

Act on the Consumer Protection in Electronic Commerce, Etc.

Article 6 of the Act on the Consumer Protection in Electronic Commerce

In an electronic commerce or a mail-order sale:

· Records regarding labelling and advertising (6 months)

· Records regarding execution or withdrawal of a contract (5 years)

· Records regarding the payment of a price and the supply of goods and services (5 years)

· Records regarding customer services or dispute resolution (3 years)

Protection of Communications Secrets Act

Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications Secrets Act

· Log records, IP address (3 months)

· The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

Your Rights

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 Information Protection Act (“PIPA”).

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

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

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

Additional Use and Provision of Personal Information

In accordance with the PIPA, we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc. We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information. Specific considerations are as follows:

 

· whether the additional use/provision is related to the initial purpose of the collection;

· whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;

· whether the additional use/provision unfairly infringe on the interests of the data subject; and

· whether the necessary security measures such as pseudonymization or encryption were taken.

Domestic Privacy Representative

Pursuant to the Article 32-5 of Network Act and Article 39-11 of the amended PIPA, the information regarding the domestic agent is as follows:

· Name: Tencent Korea Yuhan Hoesa

· Address: 152 Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Korea

· Telephone Number: +82-2-2185-0902

· Email: dpo_alchemystars@proximabeta.com

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.

· Data Protection Department, responsible for the management and safety of your personal information

· Telephone: +82-2-2185-0902

· Email: dpo_alchemystars@proximabeta.com

Russia

If you are using the Game in Russia, by using the Game you consent to:

· for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations, the processing of your information in accordance with this Privacy Policy; if legitimate interests, optimisation of the Game or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law);

· the cross-border transfer of your information to any country where we have databases or affiliates, in particular Singapore; and

· for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this Privacy Policy.

 

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

We will 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 after the notification.

As regards the representative for Russia, you can contact us at dpo_alchemystars@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.

· Name: Karanovic & Partners o.a.d. Beograd

· Address: Resavska 23, Belgrade, 11000, Serbia

· Telephone Number: +381 11 3094 200

· E-mail: local.representative@karanovicpartners.com

 

Singapore

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 dpo_alchemystars@proximabeta.com.

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 dpo_alchemystars@proximabeta.com.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at dpo_alchemystars@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 “accept”, 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.

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

Thailand

By clicking “accept”, 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.

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at dpo_alchemystars@proximabeta.com.

We will give you notice by email of any changes to this Privacy Policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

Turkey

Our Data Controller Representative in Turkey is Özdağıstanli Ekici Avukatlık Ortaklığı for the purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations can be contacted at turkeydatarep_proximabeta@iptech-legal.com. Please include the word “Turkey” 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 (and to the extent permitted under applicable laws and regulations):

 

· learn whether or not your personal data has been processed;

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

· learn the purpose of processing of your personal data;

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

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

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

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

United Arab Emirates

You consent to the collection, use, disclosure, transfer, 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.