PRIVACY POLICY
Effective Date: 06. 26, 2024.
This Privacy Policy describes how NCSOFT
CORPORATION (“NCSOFT,” “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 PlayNC 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 NCSOFT 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 NCSOFT 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 NCSOFT 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 NCSOFT 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 NCSOFT 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), NCSOFT 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, NCSOFT 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;
■ “NCSOFT”, “Operator” NCSOFT
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.
NCSOFT
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.
NCSOFT
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 NCSOFT by the legislation.
■ Processing of the User’s personal data is necessary to effect rights
and legal interests of
the NCSOFT 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 NCSOFT: automated, mixed, non-automated.
In case of
confirmation of the fact of inaccuracy of personal data, NCSOFT 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 NCSOFT 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 NCSOFT through any of the communication channels listed in
the "Contact
Us" section.