Welcome to 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 and PC game Alchemy Stars outside of the United States (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.

Which versions of the Alchemy Stars game does this Privacy Policy apply to?

This Privacy Policy applies to the:

· mobile phone version of Alchemy Stars game outside of the United States; and

· PC version of Alchemy Stars game in Japan.

If you are using the United States version of the Alchemy Stars game, please refer to the United States version of the privacy policy available here: https://www .alchemystars.com/privacypolicy/us/en.html

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 have 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.	Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands	dpo_alchemystars@proximabeta.com
UK	Image Frame Investment (UK) Limited	4 ^th Floor 80 Strand, London , United Kingdom WC2R 0RL	dpo_alchemystars@proximabeta.com
Korea	Kite Bird Korea Yuhan Hoesa	25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea	dpo_alchemystars@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 10 ^th , 11 ^th & 12 ^th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand	dpo_alchemystars@proximabeta.com
Türkiye	Özdağıstanli Ekici Avukatlık Ortaklığı.	Nidakule Ataşehir Kuzey Begonya Sok. No: 3 Kat. 17 D: 162 34746 Ataşehir / İstanbul, Türkiye Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-Game conduct, suspensions, investigations, civil or criminal complaints.	turkeydatarep_proximabeta@iptech-legal.com

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime 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 Process Your Personal Information ” below.

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

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

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

· Account registration information (via social media accounts):

o Mobile phone version : When you choose to log into the Game with your social media account (Apple, Google, Facebook, X (previously known as 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, Open ID and profile picture (if any). If you register for the mobile phone version of the Game with your DMM social media account, we will collect your access token, access token expiry time, user ID, DMM games ID, and application ID in order to set up your profile

o PC version : If you register for the PC version of the Game with your DMM social media account, we will collect your user ID to set up your profile

· LEVEL INFINITE PASS Account Log-in information : If you choose to log into the Game via LEVEL INFINITE PASS account, we will collect your user ID, user token, email address, username and country.

· Survey information (optional): If you choose to participate in a survey about Alchemy Stars, you may be asked to provide certain personal information as part of your survey response.

· Customer support information: When you choose to use our Customer Service, we will process information such as your game account and contact information, login status verification information, device information, game data, customer service log data , feedback on app store and any other details/information that you choose to provide to us as part of your ticket, query or review.

b) Game - 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): Open ID, role ID, Game account, user nickname, country code, system and device information and gameplay statistics

· Survey data: User ID, Open ID, IP address, browser version, device settings and operating system version

· IP address

· For the purposes of announcements and in-game notifications: Your Open ID and device information

· Analytics (Firebase) : Open ID, device dimensions and in-app events

· 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 : Open ID 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, Open ID, system and device information

· Compliance features : Open ID, token, region, username and email address

· In-app purchases : Open ID, country, role ID, device and application information, network information, IP address, IDFA (identifier for advertisers), IP address, IDFV (identifier for vendors) and user purchase transaction record (including user ID, purchase quantity, purchase amount and transaction time)

d) PC version - DMM data and sharing – Japan only

If you have signed up to the mobile phone version of the Game with your DMM social media account, you can use your mobile phone account to play the PC version of the Game. We will process the following data when you play the PC version of the Game:

· Data sharing : Once you bind your DMM accounts, your Game data between your mobile phone and PC versions will be shared

· Payments : User information (application ID, open ID, one-time token, Open ID, virtual currency amount, device information (IP address), details about the transaction (cost, time and date, items purchased, currency, order ID, Open ID, role ID), and transaction records (payment amount, transaction time, items purchased, currency, country, order ID)

· Security :

o Hardware information: We will process information about your hardware such as manufacturer, model number, and serial number information

o User account information: We will process information about your user account such as Open ID, role ID, VPN connected information, and network information

· Crash data: Crash-related information.

2. Children

Children must not use the Game for any purpose, except where their parent or guardian has provided lawful 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 relevant minimum age in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

Jurisdiction 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
Indonesia	21
Japan	18
Kazakhstan	18
Kingdom of Saudi Arabia	18
Kuwait	21
Malaysia	18
Mexico	18
Morocco	18
Myanmar	18
New Zealand	16
Nigeria	13
Philippines	18
Qatar	18
Republic of Korea	14
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/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.

3. How We Process 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 Brazil, the European Economic Area, Indonesia, Switzerland, Thailand, Türkiye or the United Kingdom (“ 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: Open ID	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): Mobile phone version: · Apple: Apple ID, nickname, profile picture, user token and Open ID · Google : User ID, nickname, profile picture, user token and Open ID · Facebook : Facebook ID, name, profile picture, user token and Open ID · X (previously known as Twitter) : User ID, nickname, profile picture, user token and Open ID · LINE : User ID, nickname, profile picture, user token and Open ID · DMM : User ID, DMM games ID, and application ID PC version: · DMM : User ID	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
LEVEL INFINITE PASS Account Log-in information (if you choose to log in via LEVEL INFINITE PASS account): User ID, user token, email address , username, country For more details, see LEVEL INFINITE PASS Account Privacy Policy	We use this information to link your Game account to your LEVEL INFINITE PASS account in accordance with your request, and to ensure consistency across accounts.	Necessary to perform our contract with you to provide the Game.
Survey information (optional): 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, to improve the Game, to send you activation codes and allow you to redeem emoticons for participating in the survey, and to send you email communications about the Game	We collect this information with your consent
Customer support information: · game account and contact information (including your nickname, profile picture, open ID, country selected by you during registration, login channel, social media account, mobile phone, email address, registration time); · login status verification information; · device information; · game data: Game character information (including your role name and role ID, game data and records, frequency of playtime, game history), and in-game data (including items, purchase and top-up information, penalties, activities, game match data, in-game friends); · customer service log data (including Open ID, ticket date, type of request); · feedback on app store; · any other details/information (including any documents/media) that you choose to provide to us as part of your ticket, query or review	We use this information: · to improve our services; · to respond to your communications; · to provide support and troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the Game.
*Information generated as part of the Game*
Game data : Open ID	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, to optimise the Game, and to send you activation codes and allow you to redeem emoticons for participating in the survey	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) : Role ID, Game account, user nickname, system and device information, IDFV (identifier for vendors), client exports IP gameplay statistics, 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 Open ID and device and application information and guest ID	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): Open ID, device dimensions and in-app events	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 and device information and usage Technical Identifiers : User agent, IDFA (identifier for advertisers; only processed for the purpose of serving advertisements), Google Advertiser ID and Open ID Engagement Information : Information regarding your engagement with our advertising campaigns Contact Information : name, email address, and phone numbers, that are used for matching purposes only Event Data : information about you and the actions that you take in relation to the Game	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 and application information, network information, Google Advertising ID and IDFV (identifier for vendors)	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, IP address, Open ID, system information, device and application information, IDFV (identifier for vendors)	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 : Open ID, region, user name 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 : Open ID, country, role ID, device and application information, network information, IP address, IDFA (identifier for advertisers), IP address, 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
*DMM data and sharing (PC version) – Japan only*
Data sharing : Once you bind your DMM accounts, your Game data between your mobile phone and PC versions will be shared	We use this information in order to allow you to bind your mobile phone version account and play the Game on the PC	Necessary to perform our contract with you to allow you to use the Game on your PC
Payments : User information, application ID, user ID, Open ID, virtual currency amount, device information: (IP address), details about the transaction (cost, time and date, items purchased, currency, order ID, Open ID, role ID), and transaction records (payment amount, transaction time, items purchased, currency, country, order ID)	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 and allow you to make payments in the Game
Security : *Hardware information* : information about your device hardware, operating system, network and browser activity *User account information* : Open ID , role ID, network and browser activity, installed anti-virus software, crash data, user behavior and status that may be related to plug-in use and/or cheating behaviour, event tracing, known files related to cheat tools, memory and instructions during game rendering, game screenshots and configuration of cheating tools.	We use this information for security purposes in order to monitor and fight cheating behaviour to provide a fair and secure gaming environment	Legitimate interest to monitor and fight cheating behaviour to provide a fair and secure Game
Crash data: PC MAC address device and application information.	We use this information to locate and solve crash issues	Legitimate interest to ensure the security and integrity of the Game

4. How We Store and Share Your Personal Information

Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Game in Germany, Singapore, Korea and Japan. The servers applicable to your use of the Game will depend upon your location. We also have support, engineering and other teams who may support the Game, including from 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 to send SMS messages to notify you about the official launch of Alchemy Stars or to send you verification codes and communication via email, to 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 for 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 solely for the purpose of providing the Game to you. All such group companies may only use your personal information in accordance with this Privacy Policy .

· Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.

· Third parties to ensure safety, security, or compliance with laws . We may 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 (such as 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.

5. The Security of Your Personal Information

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.

6. Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

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: Open ID	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data. 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): Mobile phone version: · Apple: Apple ID, nickname, profile picture, user token and Open ID · Google : UserID, nickname, profile picture, user token and Open ID · Facebook : Facebook ID, name, profile picture, user token and Open ID · X (previously known as Twitter) : User ID, nickname, profile picture, user token and Open ID · LINE : User ID, nickname, profile picture, user token and Open ID · DMM : Access token, access token expire time, user ID, secure ID, unique ID, DMM games ID, and application ID PC version: · DMM : User ID	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data. 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. DMM account deletion: Stored for the lifetime of your use of the Game unless you request to delete the mobile phone or PC version of your Game account , in which case the data in both versions will be deleted within 30 days of 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.
LEVEL INFINITE PASS Account Log-in information (if you choose to log in via LEVEL INFINITE PASS account): User ID, user token, email address, username, country	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, after which it will be deleted within 30 days. 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 support information	For customer service log data: Stored for the lifetime of your use of the Game unless you request to delete your Game account or data, after which it will be deleted within 30 days. For game data: Processed until your support ticket, query or review has been resolved or completed. For customer support information (other than customer service log data and game data): 2 years (unless you provide sensitive data, in which case such data will be deleted after your support ticket, query or review has been resolved or completed). If you request for deletion, data will be deleted within 30 days after your request.
Game data: Open ID, 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 data. 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 Open ID 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 data.
Survey information	Automatically deleted after one year of collection unless you request to delete your Game account or data.
Announcements and in-Game notifications	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data. 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 data.
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 data.
Data analytics	Automatically deleted after 30 days of collection.
Chat data (Open ID)	Open ID: Manually deleted after one year of collection unless you contact our customer service team and request to delete your data, in which case, the data will be deleted within 7 working days of 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 .
Compliance features	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data. 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 data. 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.
*DMM data and sharing (PC version) – Japan only*
Payments	Stored for the lifetime of your use of the Game unless you request to delete your Game account or data. 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.
Security	Stored for 90 days unless you request to delete your Game account or data.
Crash data: Crash-related information	3 months

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.

7. 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, Russia, and the Kingdom of Saudi Arabia.

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 Process 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.

8. 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.

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

9. 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.

10. 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 your consent to 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

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 ).

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 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

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.

You have the right to access personal information we hold about you, how we use it, and who we share it with.

You have the right to correct any of your personal information we hold that is inaccurate.

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 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 .

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 ).

Bangladesh

By acknowledging the 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 the Privacy Policy . You also 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.

Brazil

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.

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 .

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

Your authorization to process personal information for the Game may be expressed (i) in writing, (ii) orally or (iii) through unequivocal conduct that allows us to reasonably conclude that your authorization has been 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.

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.

Egypt

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy.

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 Germany, Japan, Korea and 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

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 y our 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

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.

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.

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.

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

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.

By acknowledging the Privacy Policy, 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 Germany, Japan, Korea and Singapore.

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 .

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.

By clicking “accept”, 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 Germany, Japan, Korea and Singapore .

In the event of any discrepancy or inconsistency between the English version and the Kazakh version of this Privacy Policy, the Kazakh version shall prevail.

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

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

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 .

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.

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.

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

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.

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”.

By using the Game and providing us with your personal data, you agree to the data transfers detailed above that require your consent.

To understand more about and exercise your rights to “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us at dpo_alchemystars@proximabeta.com.

Morocco

We collect information for purposes strictly necessary for the proper use of the Game. By accepting this Privacy Policy, 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 process 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 process your personal information ” and the section “ Your Rights ” ( sub-paragraph “Objection”).

New Zealand

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.

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 .

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.

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).

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 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.

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.

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

· Contact: dpo_alchemystars@proximabeta.com

Philippines

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.

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

· collecting and processing your personal information as described in the section “ How We Process 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:

Delegatee

Description of Delegated Services

Aceville Pte Ltd

(cloudlegalnotices@tencent.com)

Storage of personal information

Midas

Provide payment function

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 ( privacy@appsflyer.com )	United States unless otherwise described in the service provider’s privacy policy	Transferred via information and communications network at the time of service use	Analytics data (Appsflyer SDK)	User acquisition	In accordance with Appsflyer’s Privacy Policy ( https://www.appsflyer.com/services-privacy-policy/ )
Facebook (Analytics) ( https://www.facebook.com/help/contact/507739850846588 )	United States unless otherwise described in the service provider’s privacy policy	Transferred via information and communications network at the time of service use	Analytics data (Facebook SDK)	User acquisition	In accordance with Facebook’s Privacy Policy ( https://www.facebook.com/policy.php )
Google Analytics (Firebase) ( https://firebase.google.com/support )	United States unless otherwise described in the service provider’s privacy policy	Transferred via information and communications network at the time of service use	Analytics data	Data analytics	In accordance with Firebase’s Privacy Policy ( https://firebase.google.com/support/privacy )
Aceville Pte Ltd ( cloudlegalnotices@tencent.com )	Singapore	Transferred via information and communications network at the time of service use	All personal information collected	Storage of personal information	For the data retention period specified under “ How We Store and Share Your Personal Information ”.
Midas (privacy@midasbuy.com)	Singapore and United States	Transferred via information and communications network when payment is made	Payment information	Payment	For the data retention period specified under “ How We Store and Share Your Personal Information ”.

You may refuse the overseas transfer of your personal information by contacting our Data Protection Department. If you refuse the overseas transfer of your personal information, your personal information will not be transferred overseas. However, you may not be able to use our services for which overseas transfer of personal information is necessary.

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 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)