PRIVACY POLICY
Effective Date: 06. 30, 2023.
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.
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.
A. 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.
B.
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.
C.
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.