PRIVACY POLICY
Effective Date: 04. 15, 2026.
1. Introduction and Overview.
This Privacy Policy describes how NC CORPORATION (“NC,” “we,”
“our,” or “us”) collects, uses, and shares information about you
as well as your rights and choices regarding such information. It applies to
our NC platform (the “Platform”), games available through the Platform
(the “Games”), streaming service available through the Platform (“Streaming
Service”), websites for the Platform, Games, and Streaming Service (the “Websites”)
and related applications (the “Apps”), and any online location operated
by us that links to this Privacy Policy (collectively, the “Service”). We
have a comprehensive company privacy policy including those for service
providers, third parties and affiliates, and operate in accordance with it.
This Privacy Policy has been established and is being operated in alignment
with our policy for protecting personal information.
By using the Service, you agree to our Terms of Use and our collection, use
and disclosure practices, and other activities as described in this Privacy
Policy. If you do not agree, discontinue use of the Service.
If you have any questions or wish to exercise your rights and choices,
please contact us as set out in the “Contact Us” section. If you are a
Nevada resident, California resident, Taiwan citizen or otherwise a data
subject as defined under Taiwan law, Japanese citizen or otherwise a data
subject as defined under Japanese law, or data subject in Europe, please
see the additional disclosures at the end of this Privacy Policy.
For personal data transferred from the United Kingdom, the European Union,
or Switzerland we will provide appropriate safeguards, such as through the use
of standard contractual clauses.
We collect information about you when you use the Service, including when you use the
Platform, play our Games, use the Streaming Service, register an account,
update your profile, access our content, sign up for a rewards program, make a
purchase, participate in a promotion, or contact customer support. We
collect information about you in a variety of ways depending on how you
interact with us;
A. Information You
Provide To Us.
Directly from you when you provide it to us with opt-in process, such as
when you register for an account, sign up to receive communications from us,
make a purchase, or contact us by phone, email, or otherwise.
The categories of information we collect when you use the Service include:
■ Contact Data, including your first and
last name, email address, phone number, and postal address.
■ Account Credentials, including your username,
password, password hints, and information for authentication and account access
(such as a PIN).
■ Billing data, including Guardian email
address, coupon codes, mobile phone personal authentication information, bank
name, and credit card company.
■ Demographic Data, including your date of
birth, gender, and country.
■ Profile Data, including your
interests, inferences, preferences and favorites.
■ Commercial or transactions information, including records of
products or services purchased, obtained, or considered.
■ Content, including content
within any messages you send to us (such as feedback and questions to customer
support) or publicly post on the Service (such as in product reviews or blog
comments). We also collect content within any messages you exchange with other
users through the Service (such as if you use our chat functionality).
■ Personal Contacts Data, including the first and last
name, email address, and phone number of your personal contacts. We collect
data about your contacts with your consent and in order to fulfill a request by
you, such as finding your contacts on the Service or inviting your contacts to
join the Service. Such functionality is only intended for U.S. residents. By
using this functionality, you acknowledge and agree that both you and your
contacts are based in the U.S. and that you have your contacts’ consent for us
to use their contact information to fulfill your request.
■ When you access third-party services, such as third-party online
gaming services and social media services -- through our services, these
third-party services may be able to collect information directly from you or
about you, including information about your activity on our services like your
account information, nickname, and profile information.
If you participate in a promotion and are declared a winner, depending on
the prize we may also collect your driver’s license number, passport number, or
other similar identifiers as set out in the applicable promotion’s additional
terms and conditions.
If you are eligible for a gift by participating in an event, we may collect
the following in order to provide the gift to you:
■ If a physical gift: name, mailing address, phone
number, and email address.
■ If a digital gift: name, mobile phone number, and
email address.
You may choose to voluntarily provide other information to us that we do
not request, and, in such instances, you are solely responsible for such
information.
B. Information
Collected Automatically.
Automatically through the use of cookies, server logs, and other similar
technologies when you play our Games or otherwise interact with our Websites,
Streaming Services, Apps, and other Services, as well as when you interact with
our advertisements, and communications.
The categories of information we automatically collect include:
■ Service Use Data, including data about
features you use, pages you visit, emails and advertisements you view, gameplay
data related to your interactions with our Platform, Games, and Streaming
Service, faulty use records, products and services you view and purchase, the
time of day you browse, and your referring and exiting pages.
■ Device Data, including data about the
type of device or browser you use, your telecommunications provider, your
device’s operating software, your internet service provider, your device’s
regional and language settings, and device identifiers such as IP address, a Global
Unique Identifier, and Ad Id.
■ Location Data, including imprecise location
data (such as location derived from an IP address or data that indicates a city
or postal code level) and, with your consent, precise location data (such
as latitude/longitude data).
The types of tracking technologies we use to automatically collect
information include:
■ Log Files, which are files that record events that occur
in connection with your use of the Service.
■ Cookies, which are small data files stored on your
device that act as a unique tag to identify your browser. We use two types of
cookies: session cookies and persistent cookies. Session cookies make it easier
for you to navigate our Websites and expire when you close your browser.
Persistent cookies help with personalizing your experience, remembering your
preferences, and supporting security features. Additionally, persistent cookies
allow us to bring you advertising both on and off the Service. Persistent
cookies may remain on your device for extended periods of time, and generally
may be controlled through your browser settings.
■ Pixels (also known as web beacons), which is code embedded
in a website, video, email, or advertisement that sends information about your
use to a server. There are various types of pixels, including image pixels
(which are small graphic images) and JavaScript pixels (which contains
JavaScript code). When you access a website, video, email, or advertisement
that contains a pixel, the pixel may permit us or a separate entity to drop or
read cookies on your browser. Pixels are used in combination with cookies
to track activity by a particular browser on a particular device. We may
incorporate pixels from separate entities, such as the Facebook SDK, that allow
us to track our conversions, bring you advertising both on and off the Service,
and provide you with additional functionality, such as the ability to connect
our Service with your social media account.
■ App Technologies, which are technologies
included in our Apps that are not browser-based like cookies and cannot be
controlled by browser settings. For example, our
Apps may include SDKs (e.g., the Facebook SDK), which is code that
sends information about your use to a server. These SDKs allow us to track
our conversions, bring you advertising both on and off the Service, and provide
you with additional functionality, such as the ability to connect our Service
with your social media account.
■ Location-Identifying Technologies, which are technologies used
to collect your location. For example, GPS, WiFi, and Bluetooth may be
used to collect precise location data when you consent to precise location
tracking through our Apps. Location data may be used for purposes
such as verifying your device’s location and delivering or restricting relevant
content and advertising based on that location.
For further information on how we use tracking technologies for analytics
and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.
C. Information
from Other Sources.
From your friends if they provide us with your contact information for
purposes of inviting you to play our Games or otherwise engage with our
Services.
We do not purchase personal information from other sources without your
consent. From other sources, including, for example, our affiliates, business
partners, service providers, online social media networks, and other third
parties, or from publicly available sources (including the public domain). For
example, if you log into your user account through social media sign-in
services (e.g., Facebook Connect). We will base these collections on your
consent where required by law.
We collect and use information for business and commercial purposes in
accordance with the practices described in this Privacy Policy. Our purposes
for collecting and using information include:
■ Operating and managing our Service.
■ Performing services requested by you, such as
responding to your comments, questions, and requests, facilitating a refund,
and providing customer service.
■ Sending you technical notices, updates, security
alerts, information regarding changes to our policies, and support and
administrative messages.
■ Preventing and addressing fraud, breach of policies or
terms, and threats or harm.
■ Monitoring
and analysing trends, usage, and activities.
■ Conducting research, including focus groups and
surveys.
■ Improving the Service and other NC websites,
apps, marketing efforts, products and services.
■ Developing and sending advertising, direct marketing,
and communications about our and other entities’ products, offers, promotions,
rewards, events, and services.
■ Conducting promotions, including verifying your
eligibility and delivering prizes in connection with your entries.
■ Fulfilling any other purpose at your direction.
■ With notice to you and your consent.
In many situations we have more than one purpose. For example, when you create an account with us we
will collect your information to perform our contract with you, but we also
collect your information as we have a legitimate interest in giving our users
the best experience possible while playing our Games. As a result, our
collection and processing of your information is based in different contexts
upon your consent, our need to perform a contract, our obligations under law,
and/or our legitimate interest in conducting our business.
Notwithstanding the above, we may use and share
information that does not identify you (including information that has been
aggregated or de-identified) for any purpose except as prohibited by applicable
law. To the extent we maintain and use such de-identified information, we will
not attempt to reidentify the information, except for the purpose of
determining whether our deidentification processes satisfy our legal
obligations. For information on your rights and choices regarding how we use
information about you, please see the “Your
Rights and Choices” section below.
We share information we collect in accordance with the practices described
in this Privacy Policy. The categories of parties with whom we share
information include:
■ Service Providers. We
share information with service providers that process information on our
behalf. Service providers assist us with services such as payment
processing, data analytics, marketing and advertising, website hosting, and
technical support. We contractually prohibit our service providers from
retaining, using, or disclosing information about you for any purpose other than
performing the services for us, although we may permit them to use
information that does not identify you (including information that has been
aggregated or de-identified) for any purpose except as prohibited by applicable
law. We conduct regular
assessments and improvements to ensure that service providers with whom we
share personal information for the purpose of service provision comply with our
privacy policy and process personal information appropriately.
■ Partners. We share information with our partners in
connection with offering co-branded services, selling or distributing our
products, or engaging in joint marketing activities.
■ Promotions and Prizes. Our promotions and prizes
may be jointly sponsored or offered by other parties. When you voluntarily
enter a promotion or collect a prize, we share information as set out in the
official rules or additional terms and conditions that govern the promotion or
prize, as well as for administrative purposes and as required by law (e.g., on
a winners list). By entering a promotion or collecting a prize, you agree to
the official rules or additional terms and conditions that govern that promotion
or mission, and acknowledge that these terms and conditions may, except where
prohibited by applicable law, allow the sponsor and/or other entities to use
your name, voice and/or likeness in advertising or marketing materials.
■ Public Forums. We share information you
make public through the Service, such as information in your profile or that
you post on public boards. Please think carefully before making information
public as you are solely responsible for any information you make public. Once
you have posted information, you may not be able to edit or delete such
information, subject to additional rights set out in the “Your Rights and
Choices” section below.
■ Merger or Acquisition. If another company acquires, or plans to acquire, our
company, business, or our assets, we may share your personal information with
that company, including at the negotiation stage.
■ Security and Compelled Disclosure. We may disclose information in response to subpoenas,
warrants, or court orders, or in connection with any legal process, or to
comply with relevant laws. We may also share your information in order to
establish or exercise our rights, to defend against a legal claim, to
investigate, prevent, or take action regarding possible illegal activities,
suspected fraud, safety of person or property, or a violation of our policies,
or to comply with your request for the shipment of products to or the provision
of services by a third-party intermediary.
■ Facilitating Requests. We share information at
your request or direction.
■ Consent. We share information in other situations
with notice to you and your consent.
Please note that we do not rent, sell for monetary consideration, or
provide personal information to third parties for purposes other than as
described above, including to complete transactions and provide the
Services.
We offer parts of our Service through websites, platforms, and services
operated or controlled by other parties. In addition, we integrate technologies
operated or controlled by other parties into parts of our Service.
Some examples include:
■ Links. Our Service includes links that hyperlink
to websites, platforms, and other services not operated
or controlled by us.
■ Logging-In. We may allow you to log-in
or create an account through social media or another platform, such as through
a Google, Facebook, Apple, Twitter, Line or Vkontakte account. If you choose to
engage with such integration, we may receive information from the platform that
you have authorized to share with us, such as your public profile name, email
address, and internal identification information. Please note that the platform
may independently collect information about you through the integration.
■ Brand Pages. We may offer our content
through social media. Any information we collect from your engagement with our
content (such as through our brand page) is treated in accordance with this
Privacy Policy. Also, if you publicly reference our Service on social media
(e.g., by using a hashtag associated with NC or the Service in a tweet or
post), we may use your reference on or in connection with our Service. Please
not that the social media provider will use your information in accordance with
their privacy policy.
■ Platform Linking. We may offer you the
ability to link your NC account to another service in order to retrieve certain
data about your account on that service. For example, if you link your account
to a gaming platform such as Steam or Twitch, the linking may allow us to
obtain information such as your gaming username, email address, photo, game
performance, and high scores. For more information about how these platforms
handle information about you, please refer to their respective privacy policies
and terms of use.
Please note that when you interact with other parties, including when you
leave our Service, those parties may independently collect information about
you and solicit information from you. The information collected and stored
by those parties remains subject to
their own policies and practices, including what information they share with
us, your rights and choices on their services and devices, and whether they
store information in the U.S. or elsewhere. We encourage you to familiarize
yourself with and consult their privacy policies and terms of use.
We use analytics services to help us
understand how users access and use the Service. In addition, we work with
agencies, advertisers, ad networks, and other technology services to place ads
about our products and services on other websites and services. For example, we place ads
through Google and Facebook that you may view on their platforms as well as on
other websites and services.
As part of this process, we may incorporate tracking technologies into our
own Service (including our Websites, Apps and emails) as well as into our ads
displayed on other websites and services. Some of
these tracking technologies may track your activities across time and services
for purposes of associating the different devices you use, and delivering
relevant ads and/or other content to you (“Interest-based Advertising”).
We also use audience matching services (which is a type of Interest-based
Advertising) to reach people (or people similar to people) who have visited our
Service or are identified in one or more of our databases (“Matched Ads”).
This is done by us providing a list of hashed email addresses to an ad partner
or incorporating a pixel from an ad partner into our own Service, and the ad
partner matching common factors between our data and their data. For instance, we
incorporate the Facebook pixel on our Service and may share your email address
with Facebook as part of our use of Facebook Custom Audiences.
As indicated above, vendors and other parties may act as our service
providers, or in certain contexts, independently decide how to process your
information. We encourage you to familiarize yourself with and consult their
privacy policies and terms of use.
For further information on the types of tracking technologies we use on the
Service and your rights and choices regarding analytics, Interest-based
Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
A. Account
Information.
You may access, update, or remove certain information that you have
provided to us through your NC account by visiting your account settings
or sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to
allow us to confirm your identity. Please note that we will retain and use
information about you as necessary to comply with our legal obligations,
resolve disputes, and enforce our agreements.
B. Tracking
Technology Choices.
■ Cookies and Pixels. Most browsers accept
cookies by default. You can instruct your browser, by changing its settings, to
decline or delete cookies. If you use multiple browsers on your device, you
will need to instruct each browser separately. Your ability to limit cookies is
subject to your browser settings and limitations.
■ Do Not Track. Your browser settings
may allow you to automatically transmit a “Do Not Track” signal to online
services you visit. Note, however, there is no industry consensus as to
what site and app operators should do with regard to these signals. Accordingly,
unless and until the law is interpreted to require us to do so, we do not
monitor or take action with respect to “Do Not Track” signals. For more
information on “Do Not Track,” visit http://www.allaboutdnt.com.
■ App and Location Technologies. You can stop all collection of
information via an App by uninstalling the App. You
can also reset your device Ad Id at any time through your device settings,
which is designed to allow you to limit the use of information collected about
you. You can stop all collection of precise location data through an
App by uninstalling the App or withdrawing your consent through your device
settings.
Please be aware that if you disable or remove tracking technologies some
parts of the Service may not function correctly.
C. Analytics and
Interest-Based Advertising.
Google provides tools to allow you to opt out of the use of certain
information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for
Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/ .
The companies we work with to
provide you with targeted ads are required by us to give you the choice to opt
out of receiving targeted ads. Most of these companies are participants of
the Digital Advertising Alliance (“DAA”) and/or the Network Advertising
Initiative (“NAI”). To learn more about the targeted ads provided by
these companies, and how to opt out of receiving certain targeted ads from
them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads
from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads
from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that
the selected participants should no longer deliver certain targeted ads to you,
but does not mean you will no longer receive any targeted content and/or ads
(e.g., in connection with the participants’ other customers or from other
technology services).
To opt out of us using your hashed email for
Matched Ads, please contact us as set forth in the “Contact Us”
section below and specify that you wish to opt out of matched ads. We will stop
sharing such information for Matched Ads.
Please note that if you opt out using any of these methods, the opt out
will only apply to the specific browser or device from which you opt out. We
are not responsible for the effectiveness of, or compliance with, any opt out
options or programs, or the accuracy of any other entities’ statements
regarding their opt out options or programs.
D. Communications.
■ E-mails. You can opt-out of receiving
promotional emails from us at any time by following the instructions as
provided in emails to click on the unsubscribe link, or emailing us at the
email address set out in the “Contact Us” section below with the word
UNSUBSCRIBE in the subject field of the email. Please note that you cannot
opt-out of non-promotional emails, such as those about your account,
transactions, servicing, or our ongoing business relations.
■ Push Notifications. If you have opted-in to
receive push notification on your device, you can opt-out at any time by
adjusting the permissions in your device or uninstalling our app.
■ Text Messages and Calls. You can opt-out of
receiving text messages or calls to your phone number at any time by (i) for
text messages, texting “STOP” in response to any text message you receive from
us or contacting us as set out in the “Contact Us” section below and specifying
you want to opt-out of text messages; and (ii) for calls, requesting opt-out
during any call you receive from us or contacting us as set out in the “Contact Us” section below and specifying
you want to opt-out of calls.
Please note that your opt out is limited to the email address, device, and
phone number used and will not affect subsequent subscriptions.
The Service is intended for general audiences, and is not directed at
children under the age of 13. We do not knowingly collect personal information
(as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from
children. If we become aware we have collected personal information in
violation of COPPA, we will remove the personal information in accordance with
COPPA. We do not knowingly “sell,” as that term is
defined under the CCPA, the personal information of minors under 16 years old
who are California residents.
If you are a California resident under 18 years
old and registered to use the Service, you can ask us to remove any content or
information you have posted on the Service. To make a request, email us at the
email address set out in “Contact Us”
section with “California Under 18 Content Removal Request” in the subject line,
and tell us what you want removed. We will make reasonable good faith efforts
to remove the post from prospective public view,
although we cannot ensure the complete or comprehensive removal of the content
and may retain the content as necessary to comply with our legal obligations,
resolve disputes, and enforce our agreements.
We implement and maintain reasonable
administrative, physical, and technical security safeguards to help protect
information about you from loss, theft, misuse and unauthorized access,
disclosure, alteration and destruction. Nevertheless, transmission via the
internet is not completely secure and we cannot guarantee the security of
information about you.
Please be aware that information collected through the Service may be
transferred to, processed, stored, and used in jurisdictions different from
your country of residence, including, without limitation, the U.S., Japan,
Korea, Singapore, Hong Kong, Thailand, Philippines, Indonesia, Europe and
Russia. Data protection laws in these other jurisdictions may be different from
those of your country of residence. Your use of the Service or provision of any
information therefore constitutes your consent to the transfer to and from,
processing, usage, sharing, and storage of information about you in other
jurisdictions as set out in this Privacy Policy. For personal data transferred
from Europe, the UK, or Switzerland, we will provide appropriate safeguards,
such as through the use of standard contractual clauses.
11. Changes to this Privacy
Policy.
We reserve the right to revise and reissue this Privacy Policy at any time.
Any changes will be effective immediately upon posting of the revised Privacy
Policy. Your continued use of our Service indicates your consent to the Privacy
Policy then posted. If the changes are material, we may provide you additional
notice to your email address.
If you have any questions or comments about this Privacy Policy, our data
practices, or our compliance with applicable law, please contact us:
By email:
By mail:
4th Fl. KTCU B/D, 192 Jungang-daero, Dong-gu, Busan, Republic of Korea
This Privacy Policy has been designed to be
accessible to people with disabilities. If you experience any difficulties
accessing the information here, please contact us at privacy@ncsoft.com
13. Additional Disclosures for
Nevada Residents.
Nevada law (NRS 603A.340) requires each business
to establish a designated request address where Nevada consumers may submit
requests directing the business not to sell certain kinds of personal
information that the business has collected or will collect about the consumer.
A sale under Nevada law is the exchange of personal information for monetary
consideration by the business to a third party for the third party to license
or sell the personal information to other third parties. If you are a Nevada consumer
and wish to submit a request relating to our compliance with Nevada law, please
contact us as at privacy@ncsoft.com
14. Additional Disclosures for
California Residents.
These additional disclosures apply only to California residents. The
California Consumer Privacy Act of 2018 (“CCPA”) provides additional
rights to know, delete and opt-out, and requires businesses collecting or
disclosing personal information to provide notices and means to exercise
rights.
A. Notice of
Collection.
In the past 12 months, we have collected the following categories of
personal information enumerated in the CCPA:
■ Identifiers, including name, postal
address, email address, phone number, online identifiers (such as IP address),
driver’s license number, passport number, or other similar identifiers.
■ Customer records.
■ Characteristics of protected classifications under
California or federal law, including gender, date of birth, and country of
residence.
■ Commercial or transactions information, including records of
rewards, promotions, products or services entered, purchased, obtained, or
considered.
■ Internet activity, including browsing history,
search history, and interactions with a website, email, application, or
advertisement.
■ Geolocation data.
■ Inferences drawn from the above
information about your predicted characteristics and preferences.
For further details on information we collect, including the sources from
which we receive information, review the “Information Collection” section above. We collect
and use these categories of personal information for the business purposes
described in the “Use of Information” section above, including to
manage our Service.
To the extent “sale” under the CCPA is interpreted to include the
activities set out in this Privacy Policy, such as those disclosed in the “Analytics and Advertising” section above, we will
comply with applicable law as to such activity. We disclose the following
categories of personal information for commercial purposes: identifiers,
characteristics, commercial or transactions information, internet activity,
geolocation data, and inferences drawn. Please review the “Sharing of Information” section above for further
details about the categories of parties with whom we share information.
B. Right to Know
and Delete.
You have the right to know certain details about our data practices in the
past 12 months. In particular, you may request the following from us:
■ The categories of personal information we have
collected about you;
■ The categories of sources from which the personal
information was collected;
■ The categories of personal information about you we
disclosed for a business purpose or sold;
■ The categories of third parties to whom the personal
information was disclosed for a business purpose or sold;
■ The business or commercial purpose for collecting or
selling the personal information; and
■ The specific pieces of personal information we have
collected about you.
In addition, you have the right to delete the personal information we have
collected from you.
To exercise any of these rights, please submit a request at privacy@ncsoft.com In the request, please
specify which right you are seeking to exercise and the scope of the request.
We will confirm receipt of your request within 10 days. We may require
specific information from you to help us verify your identity and process your
request. If we are unable to verify your identity, we may deny your requests to
know or delete.
C. Right to
Opt-Out.
To the extent NC sells your personal information as the term “sell” is
defined under the CCPA, you have the right to opt-out of the sale of your
personal information by us to third parties at any time. You may submit a
request to opt-out by clicking Do Not Sell My Personal Information or emailing us at privacy@ncsoft.com.
D. Authorized
Agent.
You can designate an authorized agent to submit requests on your behalf.
However, we will require written proof of the agent’s permission to do so and
verify your identity directly.
E. Right to
Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the
exercise of any your rights.
F. Shine the
Light.
Customers who are residents of California may request (i) a list of the categories of personal information
disclosed by us to third parties during the immediately preceding calendar year
for those third parties’ own direct marketing purposes; and (ii) a list of the
categories of third parties to whom we disclosed such information. To
exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you
are making a “California Shine the Light Request.” We may require additional
information from you to allow us to verify your identity and are only required
to respond to requests once during any calendar year.
15. Additional Disclosures for Data Subjects in Europe.
A. Roles.
B. Lawful Basis
for Processing.
Data protection laws in Europe require a “lawful
basis” for processing personal data. Our lawful bases include where: (a) you
have given consent to the processing for one or more specific purposes, either
to us or to our service providers or partners; (b) processing is necessary for
the performance of a contract with you; (c) processing is necessary for
compliance with a legal obligation; or (d) processing is necessary for the
purposes of the legitimate interests pursued by us or a third party, and your interests and
fundamental rights and freedoms do not override those interests. Where
applicable, we will transfer your personal data to third countries subject to
appropriate or suitable safeguards, such as standard contractual clauses.
C. Your Data
Subject Rights.
You have the right to access, rectify, or erase any personal data we have
collected about you. You also have the right to data portability and the right
to restrict or object to our processing of personal data we have collected
about you. In addition, you have the right to ask us not to process your
personal data (or provide it to third parties to process) for marketing
purposes or purposes materially different than for which it was originally
collected or subsequently authorized by you. You may withdraw your consent at
any time for any data processing we do based on consent you have provided to
us.
To exercise any of these rights, please contact us as set out in the “Contact Us” section above and specify
which right you are seeking to exercise. We will respond to your request within
30 days. We may require specific information from you to help us confirm your
identity and process your request.
Please note that we retain information as necessary to fulfil the purposes
for which it was collected, and may continue to retain and use information even
after a data subject request for purposes of our legitimate interests,
including as necessary to comply with our legal obligations, resolve disputes,
prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you may contact us as set out
in the “Contact Us” section above. You also have
the right to lodge a complaint with the data protection regulator in your
jurisdiction.
D. General Data
Protection Regulation (GDPR) - European Representative.
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), NC
Corporation has appointed European Data Protection Office (EDPO) as its GDPR
representative in the EU. You can contact EDPO regarding matters pertaining to
the GDPR by:
■ using EDPO’s online request form: https://edpo.com/gdpr-data-request/
■ writing to EDPO at Avenue Huart Hamoir 71, 1030
Brussels, Belgium
E. UK
General Data Protection Regulation (GDPR) – UK Representative.
Pursuant to the UK GDPR, NC Corporation has appointed EDPO UK Ltd as its UK
GDPR representative in the UK. You can contact EDPO UK regarding matters
pertaining to the UK GDPR by:
■ using EDPO UK’s online request form: https://edpo.com/uk-gdpr-data-request/
■ writing to EDPO UK at 8 Northumberland Avenue, London
WC2N 5BY, United Kingdom
16. Additional Disclosures for
Taiwan Citizen or Data Subject in Taiwan
These additional disclosures apply only to Taiwan citizens or data subjects
as defined under Taiwan law.
A. Your Data
Subject Rights.
Taiwan’s Personal Data Protection Act (“PDPA”) provides the
following rights to Taiwan citizens and data subjects in Taiwan:
■ Right to make an inquiry of and to review your
personal data;
■ Right to ask us for a copy of your personal data;
■ Right to correct or supplement your personal
data;
■ Right to demand the cessation of collection,
processing or use of your personal data; and
■ Right to delete your personal data.
We may charge a fee for providing access to your personal data. To exercise
any of these rights, please submit a request to privacy@ncsoft.com.
B. Retention
Period for Your Personal Data
We process and use the information we collect in the manner set out
under the “Information Collection” section above for a
period that is necessary to achieve the purposes set out under “Use of Information” section.
C. Territory in
Which Your Personal Data Will Be Used
We process and use the information we collect in the manner set out
under the “Information Collection” section above in
the territory where the parties provided in the “Sharing of Information” section are located
and any other territory that is necessary to achieve the purposes set out
under the “Use of Information” section.
D. Consequences of
Not Providing Your Personal Data
If you choose not to provide your personal data to us, you may not be able
to use some parts of or the entire Service. You may also be unable to receive
or use some or all of the products, services, or promotional offers provided by
us via use of the Service.
17. Additional Terms for
Residents in Japan.
A. Parental
Consent
If you are 15 years old of age or younger, please obtain consent of your
parents or legal representative before agreeing to this Privacy Policy.
B. Sensitive Information
We do not collect or provide to a third party, without your consent,
"special care-required personal information" about you, including
race, creed, social status, medical history, criminal record, fact of having
suffered damage by a crime, physical, intellectual or mental disabilities,
results of a medical check-up or other examination, guidance for the
improvement of the mental and physical conditions, or medical care or
prescription, arrest, search, seizure, detention, institution of prosecution or
other procedures related to a criminal case, or investigation, measure for
observation and protection, hearing and decision, protective measure or other
procedures related to a juvenile protection case.
C. International
Transfer
When we share your information in accordance with Section 4, the information about you
may be transferred to, or processed, stored, and used by third parties in
jurisdictions outside Japan, including the U.S., Korea, Singapore, Hong Kong,
Thailand, Philippines, Indonesia and Russia. Your use of the Service or provision
of any information constitutes your consent to the transfer to and, processing,
usage, sharing, and storage of information about you by such third parties in
other jurisdictions. If you do not agree to transfer to, or processing, usage,
sharing, and storage of information about you by such third parties in other
jurisdictions, please refrain from using the Service or providing information
about you.
18. Additional Disclosures for Data Subjects in Russian Federation
A. Definitions.
■ “Personal data” any information relating
to a directly or indirectly identified or identifiable individual (personal
data subject);
■ “Processing of personal data” any action (operation)
or a set of actions (operations) performed with or without the use of
automation with personal data, including the collection, recording,
systematization, accumulation, storage, specification (updating, modification),
extraction, use, transfer (provision, access), depersonalization, blocking,
deletion, destruction of personal data;
■ “NC”, “Operator” NC CORPORATION being the
operator of personal data;
■ “Subject of personal data”, “User” an individual (data
subject) who has agreed to our Terms of Use.
B. Purposes of
personal data collection.
NC collects and
processes personal data for a specific, predetermined and lawful purpose: to
provide services to the user under the contract comprising of the Terms of
Service and End User License Agreement, which includes specific directions
mentioned in section 3 “Use of
Information” of this
Privacy Policy. The categories of personal data that we process under the terms
of this Privacy Policy are also set out in the “Information
You Provide To Us” section.
C. Legal basis for
processing of personal data.
NC processes Users'
personal data on the following legal grounds:
■ Execution of a contract – the Terms of Service
and End User License Agreement to which the User is a party;
■ Consent to the processing of personal data (e.g., when
the User has checked the box on the consent to the processing of personal data
contained in the interactive forms);
■ Processing of the User's personal data is necessary to
perform the duties, functions, powers entrusted to NC by the legislation.
■ Processing of the User’s personal data is necessary to
effect rights and legal interests of
the NC or third parties, or to achieve publicly significant goals, provided
that the User’s rights and freedoms are not violated.
D. Procedure and conditions of personal data processing.
(a) the
list of actions performed by the operator with personal data of users:
collection, recording, systematization, accumulation, storage, specification
(updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction
of personal data;
(b) methods
of personal data processing used by NC: automated, mixed,
non-automated.
In case of
confirmation of the fact of inaccuracy of personal data, NC ensures updating
personal data.
E. Retention
Period for Your Personal Data
We process and use
the personal data we collect in the manner set out under the “Information
Collection” section
above for a period that is necessary to achieve the purposes set out under
“Use of
Information”
section.
F. Conditions for
the termination of personal data processing.
The processing of
personal data ceases if at least one of the following conditions is met:
■ User has
unilaterally withdrawn from the Terms of Service and End User License
Agreement;
■ The User
has withdrawn his consent to the processing of personal data;
■ The
predetermined purpose of processing personal data has been achieved;
■ The
period of validity of the consent to the processing of personal data has
expired;
■ Unauthorized
processing of personal data was detected.
G. Rights of the
User as a subject of personal data.
The User has the
right to receive his personal data for familiarization and to demand
from NC their rectification, blocking or destruction in case they are
incomplete, outdated, inaccurate, illegally obtained or not required for the
stated purpose of processing. In addition, Users have the right to receive
information that concerns the processing of their personal data. Users have the
right to protect their rights and legitimate interests, including compensation
for losses and (or) compensation for moral harm in court.
Users may refuse to
process their personal data at any time by contacting NC through any of
the communication channels listed in the "Contact
Us" section.