1. Introduction
KRAFTON, Inc. (“we”, “our”, “Company” or “us”) collect, use and process information about you (“you”, “user”, or “player”). We provide various services related to the Game (i.e. game, website, event, survey, or customer service) ("Games and Services"). This Privacy Policy (“Policy”) covers the personal information that is provided, collected, or generated when you access, use or subscribe to our Games and Services, except where separate privacy policies or terms and conditions apply. This Policy applies to our Games and Services and also explains the rights and choices you have with respect to this data, and how you can communicate with us. This Policy does not apply to and cannot control activities when you click or visit to other sites from our Game and Services.
We will occasionally update this Policy. When we do, we will revise the effective date above. While we will periodically inform you of this Policy or any material changes to it, your continued use of our Games and Services after such changes means you accept the Policy as revised. We encourage you to periodically review this Policy to stay informed about how we collect and process your personal information. From time to time, we may ask you to confirm your acceptance of this Policy when we offer our Games and Services.
2. What Information Do We Collect
We will collect the following categories of information that may directly or indirectly identify or describe you or your device or information that may be reasonably capable of being associated with or reasonably linked to you or your device. The information you provide to us may differ depending on the circumstances. For example, these include:
a. Identifiers, such as SteamID64(*), nickname, name, IP address, email address, postal address, phone number, date of birth, gender, country of residence, language, nationality, etc.,
b. Internet or other electronic network activity information, such as browsing behavior and device information while using our Games and Services (i.e. device model, OS version, MAC address, device ID, network type, time zone settings, battery status, screen resolution, etc.), etc.
c. Game information, such as information about crash report and system activity details (i.e. game setting, play date/time, etc.),
d. Transaction information, such as purchase date, items, etc.
When you participate in social features (such as in-game chat), the information that you disclose is public information. We may store and access it, and it may be read, copied, collected or used by other users without your consent.
(*) We collect certain information from your third party platform’s profile/account(account for Valve Corporation) as permitted by the terms of the third party platform and your privacy settings thereon..
We use this data to operate and improve our Game and Services. Some of this information is collected through our use of cookies and related online tools/technologies. See our “Cookies and Related Technologies” section below for more information.
3. How We Use Your Information
We use the collected information for a variety of purposes, primarily, to provide the Games and Services to players like you and to improve the quality of our Games and Services. These include:
1) To operate and provide our Games and Services;
2) To develop new games, improve the quality of our Games and Services, and fix bugs;
3) To detect and act upon the illegal or unauthorized use of our Games and Services;
4) To manage inquiries and requests from you (e.g. refund items in-game, etc.);
5) To provide advertising information and other information on marketing and promotional events and surveys;
6) To track usage patterns, analyze trends of users, and calculate statistics on Games and Services;
7) To prepare user statistics and provide in-game metrics (such as a leaderboard);
8) To operate Esports and provide opportunities participate in tournament(s);
9) To prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, cheating, hacking or criminal activity; and
10) To comply with and enforce legal requirements, agreements, and policies.
Most of the time, our processing of your personal information is necessary to respond to you or process your request. We may also process your information to comply with a relevant legal obligation. From time to time, we may ask for your consent to use your information for specific reasons. Where consent was provided and is required, you may withdraw your consent at any time by contacting us at the address provided in this Policy.
4. How We Share Your Information
We share certain personal information with third parties to provide our Games and Services to you, including service providers that process personal information on behalf of us to provide our Games and Services to you, like customer support and to manage our community. Some examples of these third parties are provided below. But we do not share your information with third parties for cross-context behavioral advertising.
1) third party program restriction providers to block cheating tools and unauthorized programs;
2) anti-cheating detection providers, fraud prevention vendors to provide a safe and fair gaming environment,
3) cloud computing service providers to provide cloud storage services;
4) payment service providers to assist with payment for transactions or providing withdrawing service for sellers;
5) marketing platforms and providers of analytics services relating to player behavior, in order to tailor the Service and to conduct marketing activities;
6) online survey service providers in order to improve the game service;
7) customer service providers to answer users’ inquiries;
8) delivery service providers to deliver goods to players; and
9) real-time voice transmission platform providers to provide voice chat services.
We may share your information where such disclosure is essential to comply with a legal obligation or a lawful data access request, pursuant to a merger or acquisition, with our affiliates(LIST: https://krafton.com/en/studios/) for the purposes described in this Policy, or where you have otherwise provided your consent or at your direction.
5. Cookies and Related Technologies
We use cookies, and other technologies to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes. Approved third parties may also set cookies and related technologies when you use our Games and Services.
1) Cookies
Cookies are small files downloaded to your computer (if your browser is enabled to accept cookies) to track movements within websites and to customize your experience within the website. Most Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of our websites may not function properly.
We do not control cookies in third party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. Ads appearing on our websites may be delivered to you by third-party advertising companies. These companies may use information about your visits to our websites in order to provide advertisements to you and other sites about goods and services that may be of interest to you.
2) Website Analytics
We use analytics services on our websites to allow us to record information on the use of this Site and to constantly improve our offering.
Our Games and Services uses Google® Analytics, a web analysis services offered by Google Inc. (“Google”). We may use the following advertising functions of Google® Analytics and collect personal information as provided by Google, and you may withdraw your consent by deactivating such functions in Google’s advertising settings: Remarketing by using Google® Analytics; Google® Display Network Exposure Report; Google® Analytics Demographics and Interests Report; and Integrated service allowing the collection of data through Google® Analytics by using advertising cookies and anonymous IDs.
More information about Google’s own privacy policy can be found at https://www.google.com/policies/privacy
If you wish to opt-out from your information or data being used by Google Analytics, you may download the Google Analytics Opt-out Browser Add-on available here: https://tools.google.com/dlpage/gaoptout
3) Sizmek
Sizmek collects anonymous information from players visiting the Sites utilized allow Sizmek to collect this information entirely anonymously and allow us to deliver interest-based advertising. More information about Sizmek’s own privacy policy and how to opt out can be found at https://www.sizmek.com/privacy-policy/
4) Anti-Cheat and Fraud Prevention Technology
We strive to provide a safe and fair gaming environment for all players. When you play the Game, we or third parties may use cookies and similar technologies, or collect data about your machine or device, for fraud prevention, security and authentication purposes.
6. International Data Transfers
We operate globally and to provide our Games and Services may transfer your data to countries and other regions outside of the country where you are located. If your personal information is transferred, stored or processed by us, we take reasonable steps to safeguard the privacy of your personal information, including entering into confidentiality and standard contractual clauses with vendors where appropriate. Additional information concerning the international transfer of your information is available depending on your region. See the supplemental terms section below for more information.
7. Retaining and Deleting Personal Information
In principle, we will remove your personal information without delay after the purpose of collecting personal information is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using technical measures in a way that the information cannot be reproduced. However, we may retain your personal information even after you have closed your account with us or we have ceased providing Services to you, if retention of your personal information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Policy or any other agreement we may have with a player.
8. Our Policy Concerning Children
We do not knowingly collect, use or share any information about children under 18. without verifiable parental consent or as permitted by law. If you are a parent or guardian and you believe your child has provided us with information, you can contact us and request your child’s information to be deleted from our system.
9. Links and Third-Party Services
If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave our website and go to the website you selected. Because we cannot control the activities of third parties, we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to our Games and Services, you should consult that site’s privacy policy before providing any personal information.
10. Security of Your Information
We have put in place appropriate security measures, including encryption and de-identification, to protect your personal information. In addition, we limit access to your personal information to those employees, agents, persons, or companies who have a business need to know or access the information. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality where appropriate. Please note, however, that no data transmission over the internet is 100% secure, and that complete security of any information we collect and use therefore cannot be guaranteed. Our information protection activities are annually audited by external authorities consistent with the Korean information security standard ISMS-P (Personal Information & Information Security Management System).
11. Your Privacy Rights
Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information. To make a request concerning your rights or if you have any other question, please contact us by sending an email to the address specified in the “13. Contact Us” section. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
12. Amendments
We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Games and Services. If we make material changes, we will post a prominent notice on our websites or in our Games and Services or give you other reasonable notice before any material changes take effect. All other changes are effective upon posting.
13. Contact Us
If you have any questions about this Policy, or your dealings with our Games and Services, please contact us by sending an email to privacy@krafton.com.
This Privacy Policy has been translated into other languages for your convenience. In case of any discrepancies between the English version and the other versions, the English version shall prevail. However, Korean Privacy Policy shall prevail for users based in Korea.
Appendix. SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC
This portion of our Policy applies to residents of the jurisdictions indicated below. In the event of a conflict between the Policy and this section, this section supersedes and controls.
1. EEA and UK
If you are in the European Economic Area (EEA) or the UK, you may lodge a complaint with an applicable data protection authority for your country or region where an alleged infringement of applicable data protection law occurs.
Our representative in the EU is VeraSafe Netherlands BV, located at Keizersgracht 555, 1017 DR Amsterdam, Netherlands. To contact them, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.
Our representative in the UK is VeraSafe United Kingdom Ltd., located at 37 Albert Embankment, London SE1 7TL, United Kingdom. To contact them, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.
1) International Data Transfer
If we transfer your data outside of the EEA to a country that is not recognized by the European Commission as ensuring an adequate level of data protection, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the latest standard contractual clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for personal data). You may ask for a copy of such appropriate measures by contacting us as set out in this Policy. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
2) Your Privacy Rights
You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with may be that of your habitual residence, where you work, or where we are established.
2. India
1) Our Policy Concerning Underage Users
This Game and/or Service are not intended for underage users. Thus, underage users should not use the Game and/or Service unless parental consent is provided. We do not knowingly collect, use or share any personal information for those who are under 18 years of age without the consent and verification of the underage users’ parent or guardian, or unless permitted by law. If you are under the age of 18 years, you will be asked to provide the mobile phone number of your parent or guardian to confirm that you are legally eligible to play the game. If you are a parent or guardian and you believe your child under 18 years of age has provided us with their personal information without your consent, you can contact us and request that your child’s information be deleted from our system.
2) Sensitive Personal Information
We can collect sensitive information (payment information, Proof ID number, etc.) while we are operating our Games or using our Service. We should collect or process your sensitive information under your consent.
3) International data transfers
For Indian users, your personal information will be stored and processed on our secure servers located in India and Singapore. The access to your personal information is limited to our employees, agents and contracted third parties who are bound by strict confidentiality agreements and have access only on a business need-to-know basis. Separately, we may transfer your data to contracted third party service providers, who may be in different country or region, to operate the game service and/or to meet any legal requirements. In the event of transfer to another country or region, we will take steps to ensure that your information receives the same level of protection as if it had remained in India. And if we transfer your information to other countries, we protect your personal information with multiple layers of security, including leading encryption technology.
3. Japan
If you are a resident in Japan, for any questions or issues in relation to the collection and handling of your personal information, you may reach out to our Chief Privacy Officer by sending an email to privacy@krafton.com. We will respond to your concerns and queries at the earliest and in compliance with Japanese Act on the Protection of Personal Information (“Japanese APPI”).
1) Joint Use of Your Personal Data
We may use your personal data (definition thereof shall follow the same under then-effective Japanese Act on the Protection of Personal Information) jointly with our affiliates as follows.
- Personal data used jointly
Any and all of your personal data that we collected in accordance with this Policy, whether directly, automatically or through third parties, including but not limited to;
a. Identifiers, such as SteamID64, nickname, name, IP address, email address, postal address, phone number, date of birth, gender, country of residence, language, nationality, etc.,
b. Internet or other electronic network activity information, such as browsing behavior and device information while using our Games and Services (i.e. device model, OS version, MAC address, device ID, network type, time zone settings, battery status, screen resolution, etc.), etc.
c. Game information, such as information about crash report and system activity details (i.e. game setting, play date/time, etc.)
- Scope of joint users
KRAFTON, Inc. PUBG Japan K.K and our affiliates (LIST: https://krafton.com/en/studios/)
- Purpose of use by the joint users
For the purposes described specified in “3. How We Use Your Information” in this Policy.
- Party responsible for management of the personal data
Name of the party: KRAFTON, Inc. (More Information: https://krafton.com/en/ir/governance/directors/composition/)
Address: 231, Teheran-ro, Gangnam-gu, Seoul, Republic of Korea 06142
2) International Data Transfer
If we transfer your data outside of Japan to a country that is not recognized by Personal Information Protection Commission as establishing a personal information protection system recognized to have equivalent standards the same in Japan, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the reasonable standard measures following the requirements of Section 1 of Chapter 4 in Japanese APPI. You may ask for a copy of such appropriate measures by contacting us by sending an email to privacy@krafton.com. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
3) Your Privacy Rights
You have a right to request disclosure of your personal data retained by us (“Retained Personal Data”) and purpose of use thereof, disclosure of records of third party transfer, correction, addition, deletion and discontinuance of the use and third party transfer of the Retained Personal Data. To make a request concerning your rights above, please contact us by sending an email to privacy@krafton.com.
4. United States
1) Nevada
If you are a Nevada resident, we do not sell your personal information as that term is defined under state law, Nonetheless, if you are Nevada residents who purchased our game items or goods from us, you may submit a request to record your preference to opt out for the future.
2) California
If you are a California resident, you may have additional rights as detailed below. Within the preceding 12 months, we have collected the following categories of personal information about you:
a. Identifiers, such as SteamID64, nickname, name, IP address, email address, postal address, phone number, date of birth, gender, country of residence, language, nationality, etc.,
b. Internet or other electronic network activity information, such as browsing behavior and device information while using our Games and Services (i.e. device model, OS version, MAC address, device ID, network type, time zone settings, battery status, screen resolution, etc.), etc.
c. Game information, such as information about crash report and system activity details (i.e. game setting, play date/time, etc.),
We use your personal information listed above to operate or provide Games and Services. For more details about using your personal information, you can check “3. How We Use Your Information”.
Within the preceding 12 months, we have disclosed for a business purpose your personal information to:
a. Platform provider, chatting service providers, block cheating tools provider, cloud storage service provider, payment service provider, marketing platform services, online survey service provider, customer service provider, deliver service providers.
Also, we may provide service providers or third parties with certain personal information to provide or improve our services. We determine the retention period for each of the categories of personal information listed above based on:
a. any legal or regulatory requirements applicable to such information
b. provides and operate Games and Services.
- Your California Privacy Rights
You may exercise the following rights at any point in time in connection with your personal information. To exercise such rights, please email us at privacy@krafton.com or visit our support page to request your rights.
Please note that at least your email address will be required to submit a request, and additional information may be required so we can verify you. If you exercise your rights via email, you must specify the right(s) you wish to exercise.
We will verify your identity and respond to your request within 45 calendar days. If necessary, we can take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, provided that we notify you to explain the reason for the delay.
a. Right to Know & Right to Access
You have the right to request the following information from us up to two times within a 12-month period:
- the categories of personal information that we have collected from you over the past 12 months, and the specific pieces of personal information we have collected from you;
- categories of the sources from which personal information was collected;
- business or commercial purposes for which personal information is collected;
- the categories of personal information that we have disclosed for a business purpose or sold during the past 12 months, and categories of third parties to whom the information was disclosed or sold (if applicable).
b. Right to Delete
You have the right to request that the personal information collected from you be deleted.
c. Right to Correct
You have the right to correct your personal information. You can edit your personal information in-game “Setting” menu or contact us through email for your rights.
d. Right to Non-Discrimination
You have the right not to be discriminated against for exercising these privacy rights.
e. Right to opt-out of Selling and Sharing
You have the right to opt-out of the selling and sharing of your personal information as defined by California law by requesting that your personal information not be sold or shared in any form. For targeted advertising you can control the sharing of your personal information for targeted advertising through our website. You can opt-out your advertising cookies through our cookie banner.
HOWEVER, WE HAVE NOT “SOLD” PERSONAL INFORMATION TO THIRD PARTIES AS THAT TERMS IS DEFINED BY THE CCPA WITHIN THE PAST 12 MONTHS. ALSO, WE HAVE NOT “SHARE” PERSONAL INFORMATION WITH THIRD PARTIES FOR THE CROSS-CONTEXT BEHAVIORAL ADVERTISING.
f. Rights for California Minors
Minors under the age of 16 have the right to request the deletion of and/or obtain information posted on websites such as forums or bulletin boards.
g. Shine the Light
You have the right to request the categories of the personal information that we disclosed to third parties for their direct marketing purposes during the past 12 months and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for their direct marketing purposes.
h. Limit Use and/or Disclosure of Sensitive Personal Information
You have the right to limit our use of their sensitive personal information. WE DO NOT USE YOUR SENSITIVE PERSONAL INFORMATION for purposes that require us to offer this limitation options. When we collect your sensitive personal information we will get a consent from you.
- Authorized Agent
You may designate another person or entity (“authorized agent”) to act on your behalf in connection with your request for rights that are guaranteed by the CCPA. An authorized agent is a natural person or business entity registered with the Secretary of State to conduct business in California that you have authorized to act of your behalf to make a request to know or to delete.
In order to use an authorized agent for your request, we require that you provide signed permission to your agent. Your authorized agent can submit a request to know or delete by sending an email to privacy@krafton.com. If you contact us, we can offer you an authorized form for your agent to submit.
The above requirement does not apply should your agent have power of attorney pursuant to Probate Code sections 4000 to 4465. Please note that we may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Under the CCPA, your agent is responsible for implementing and maintaining reasonable security procedures and practices to protect your information and use your personal information only for the purpose of fulfilling your request.
If you have any questions about this Policy, or about exercising your rights described above, you can contact us by email at privacy@krafton.com.
3) Virginia
If you are a Virginia resident, you may have additional rights as detailed below. Please note that at least your email address will be required to submit a request, and additional information may be required so we can verify you. If you exercise your rights via email, you must specify the right(s) you wish to exercise.
- Privacy Rights for Virginia Residents
a. Right to Delete
You have the right to request that the personal information collected from you be deleted.
b. Right to Know, Right to Access & Data Portability
You have the right to request access to personal data collected from you. Subject to limitations imposed by law, you also have the right to obtain a copy of your personal data.
c. Right to Correct
You have the right to correct your personal information. You can edit your personal information in-game “Setting” menu or contact us through email for your rights.
d. Right to Appeal
If we decline to take any action in any request that you submit in connection with the rights described in the above sections, you may ask that we reconsider our response by sending an email from which you receive the decision. Requests to reconsider must be made within 45 days after receiving the appeal.
e. Right to Non-Discrimination
You have the right not to be discriminated against for exercising these privacy rights.
If you have any questions about this Policy, or about exercising your rights described above, you can contact us by email at privacy@krafton.com.