Privacy Policy
1. INTRODUCTION
This
Privacy Policy explains the when, how and why when it comes to the processing
of your personal information in connection with the game, the Legend of Heroes:
Gagharv Trilogy (the “Game”), and sets out your choices and rights in relation
to that information. Please read it carefully – it will allow you to understand
how we collect and use your information, and how you can control it.
Please
note that this Privacy Policy only applies to the Game. If you use any other
products or services please refer to the Privacy Policy for that particular
product or service.
If you
do not agree to the processing of your personal information in the way this
Privacy Policy describes, please do not provide your information when requested
and stop using the Game. By using the Game you are acknowledging how we process
your personal information as described in this Privacy Policy.
For
the purpose of data protection laws, the data controller of your personal
information in relation to the Game is FOWGAMES (“we”, “us”, “our”).
This Policy has been
prepared with Personal information protection act from the Republic of Korea.
We also ensure that we provide service in compliance with international policy,
including the California Consumer Privacy Act (CCPA).
2.
PERSONAL INFORMATION CATEGORIES FOR DATA COLLECTION
To
provide a smooth service, The Company collects only the necessary information
after your consent. Please review the methods below:
1)
Categories of collecting personal information
Ø The following information will be
collected upon registration.
l Google: User Identification
information
l Apple: User Identification
information
l Facebook: User identification
Information
l Twitter: User identification
information
Ø When using the account linking through
Google ID, Apple ID, Facebook, or other official community, we will not collect
additional information other than the information provided by the
platform.
2)
To use the service, the following information may be
collected.
Ø Game-Related Information:
l IP Information
l Game and Service Usage Log
l Connection Log
l Purchase History
l User History
l Game Version
Ø Mobile Device Information:
l Model name
l Mobile Operator Information
l OS information
l Language(s)
l Country
l Unique Device Number
l Advertisement ID
l Cookie(s)
3)
The Following Additional Information May be Collected.
Ø The Company may collect additional
information when using the following customer-related services. We may
also request consent to collect and use personal information by law.
l Service Name
l Guild Name
l Character Name
l Device information
l OS version
l Purchase Date
l Account Information Related to the
Purchase
l Purchase Number
l Item Name
l Purchase Amount
l IP Address
l Web-Browser Information
Ø Participation of Event and Promotion:
l Server Name
l IGN
l Guild Name
l Contact Information
Ø Winning of Event and Promotion:
l Name
l Contact Information
l Unique Number
3. HOW
DOES THE COMPANY COLLECT PERSONAL INFORMATION?
1)
We collect personal information with your consent during
the sign-up process for our services.
2)
When we collect personal information, it is done through a
separate consent process during participation in events and promotions.
3)
We only collect personal information voluntarily provided by the
customer during customer service.
4)
Lastly, we collect personal information via third-party partners
or affiliated companies.
4.
PURPOSE OF COLLECTING AND USAGE OF PERSONAL INFORMATION
The
Company never discloses the collected personal information without the user’s
permission and collected personal information will be used only for the
following purposes.
1)
Implementation of the Service Contract and Compensation
Settlement:
Ø Regarding the information related to
the service contract and compensation settlement, we will collect the following
information.
l Providing Contents
l Purchase
l Payment
l Refund
l Product Delivery
l Personal Verification
l Fee collection
2)
User Management:
Ø Regarding the user management, we are
collecting the information with the following purposes:
l Personal Identification
l Prevention of illegal use
l Confirmation of Your Intention to Join
l Limitation
on the Registration and Registration Numbers
l Preservation of Information for Dispute
Settlement, Complaint Handling and Caring, Delivering of Notices.
3)
Service Development & Marketing Analysis:
Ø We may collect the information to
provide the opportunity to participate or deliver information about new service
development, events, and promotions based on statistical analysis from the
frequency of users’ access and usage.
5.
DATA RETENTION
In principle, we will promptly remove
your personal information once the purpose of collecting personal information
has been achieved. Personal information stored in physical form will be
shredded or incinerated, and personal information stored electronically will be
removed using technical measures in a way that the information cannot be
reproduced.
However, we may retain your personal
information even after you have closed your account with us or we have ceased
providing Services to you, if retention of your personal information is
reasonably necessary to comply with our legal obligations, meet regulatory
requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce
this Policy or any other agreement we may have with you.
1)
Login information: 1 year (Act on Promotion of Information and
Communication Network Utilization and Information Protection)
2)
Service-related information: 3 months (Telecommunications Secrets
Protection Act)
3)
Records related to consumer complaints or dispute resolution: 3
years (Act on Consumer Protection in Electronic Commerce, etc.)
4)
Records related to contracts or withdrawal of subscription: 5
years (Act on Consumer Protection in Electronic Commerce, etc.)
5)
Records related to payment and supply of goods: 5 years (Act on
Consumer Protection in Electronic Commerce, etc.)
6. PROCEDURE
AND METHOD OF DESTRUCTION OF PERSONAL INFORMATION
In principle, The Company
destroys the information without delay after the purpose of collecting and
using personal information is achieved. The destruction procedure and method
are as follows.
1)
Destruction procedure
The information entered by the user for user registration, etc.,
is destroyed after it is retained for a certain period for reasons for
information protection according to internal policies and laws after the
purpose of collecting and using personal information is achieved.
2)
Destruction method
-Personal information preserved in electronic files will be
deleted using a technical method that cannot reproduce the record.
-Personal information printed on paper will be shredded with a
shredder or incinerated and destroyed.
7. MEASURES TO ENSURE THE
SECURITY OF PERSONAL INFORMATION
The Company takes measures under
Article 29 of the Korea’s Personal Information Protection Act to prevent the
loss, theft, leakage, alteration, or damage of personal information while
handling members' personal data. These measures encompass both technological
and managerial approaches, as outlined below:
1)
Encryption of designated items
specified by relevant laws is implemented for storage, and confirmation or
alteration of personal information is only possible upon the individual's
request.
2)
Measures such as intrusion
prevention devices and firewalls are utilized to block external attacks, such
as hacking, to prevent leakage or tampering of members' personal information.
3)
The Company has established a
system for regular backup of personal information to prepare for contingencies.
4)
Access to users' personal
information is restricted to the minimum necessary personnel, including the
following individuals:
1.
Individuals who directly engage
in marketing activities targeting users.
2.
Individuals responsible for the
personal information management tasks, including the personal information
complaint handling department and personnel.
3.
Others who unavoidably handle
personal information in the course of their duties.
5)
The Company conducts regular
internal training for employees handling personal information on acquiring new
security technologies and obligations related to personal information
protection.
6)
The Company has established
internal procedures to prevent information leakage by individuals through
security pledges signed by all employees upon joining and to audit compliance
with the personal information processing policy and employee adherence.
7)
The Company does not hold
responsibility for personal information leaks caused by user error or the
inherent risks of the internet. Users are responsible for managing their
accounts and passwords properly to protect their personal information.
8. SERVICE FOR COMPLAINTS
REGARDING PERSONAL INFORMATION
The Company provides complaint
services related to personal information to address any grievances or concerns
users may have regarding their personal data. Users can report complaints by
referring to the contact information provided in Section 9, Personal
Information Manager and Officer, and The Company will respond promptly and
adequately to the received complaints.
For any other inquiries or
consultations regarding personal information breaches, users are advised to
contact the following agencies:
Ø Infringement
Report Center (http://privacy.kisa.or.kr /
Call 118 without area code)
Ø Cyber
Investigation Division, Scientific Investigation Department, Supreme
Prosecutor’s Office (http://www.spo.go.kr /
Call 1301 without area code)
Ø Cyber
Terror Response Center of the Korean National Police Agency
(http://www.ctrc.go.kr / Call 182
without area code)
9. CONSULTATION AND INQUIRIES
CONCERNING PERSONAL INFORMATION
The Company designates a person
in charge of protecting personal information to protect users’ personal
information and handle complaints about personal information.
1)
Privacy Protection Administrator
Name/Position: Imo Se / Team
Leader
Department: Business Operations
Department
Phone: 070-4888-0652
Email: cs@fowgames.com
2)
Personal Information Management
Officer
Name/Position: Ju Byung-ho / Manager.
Department: Business Operations Department
Phone: 070-4888-0653
Email: cs@fowgames.com
10. COOKIES
11. MATTERS CONCERNING THE INSTALLATION,
OPERATION, AND REFUSAL OF DEVICES THAT AUTOMATICALLY COLLECT PERSONAL
INFORMATION
FowGames uses cookies (hereinafter referred to as
"cookies") to store and periodically retrieve usage information to
provide individualized custom services. Cookies are small pieces of information
sent by the server (http) operating the website to the user's computer browser,
and they may be stored on the users' PC hard drive.
1)
Purpose of Cookie Usage
Cookies are used to track users' visits and usage patterns on
various services and websites, including popular search terms and secure access
status, to provide optimized information to users.
2)
Installation, Operation, and
Refusal of Cookies
You can refuse to store cookies by adjusting options in the Tools
> Internet Options > Privacy menu of your web browser.
3)
Refusing to store cookies may
cause difficulties in using customized services.
12.
CHINDREN’S PRIVACY
Generally,
we direct our Services to a general audience, and we do not knowingly collect
personal information from children under 13 years old (or older, if applicable
law provides for different protections). We may direct certain Services to an
audience of all ages---including children. For these Services, we may restrict
the collection of personal information on the Services from anyone, apply an
age gate allowing children to use the Services while restricting the collection
of personal information on the Services from children, or get a parent's
permission to collect personal information from children.
If we
become aware that a child has provided personal information without a parent's
permission, we will promptly delete this information. We encourage parents to
instruct their children to never give out their real names, addresses, or phone
numbers, without permission, when using the Internet.
13.
CALIFORNIA
This
section applies to California residents covered by the California Consumer
Privacy Act of 2018 (CCPA).
1)
Collection and Disclosure of
Personal Information
Ø Over
the past 12 months, we have collected and disclosed the following categories of
personal information from or about you or your device:
l Identifiers,
such as your name as it appears on your third-party platform profile, username,
Open ID, player ID, user ID, role ID, account ID, character ID, user token,
IDFV, IDFA, Google Advertising ID, XWID, IP address, email address, and
username. This information is collected directly from you and your device and
from third-party platforms if you choose to sign up using a third-party
account.
l Geolocation
data such as your region location provided by you or region derived from your
IP address when you set up your account. This information is collected directly
from you or your device.
l Internet
or other electronic network activity information, such as your information
regarding your use of the Game, including level, gameplay statistics, date and
time stamps of actions, log-in and how you interact with the Game and
advertisements for the Game and other device and network information as
described in the main Privacy Policy. This information is collected directly
from you and your device.
l Commercial
information about any transactions within the Game such as what products were
purchased and how much they cost. This information is collected directly from
you and your device and the Google Play or Apple iOS store.
l Audio
and visual information such as your third-party platform profile picture,
photos shared in the Game, and voice chat and messages. This information is
collected directly from you and from third-party platforms if you choose to
sign up using a third-party account.
l Other
information described in subdivision (e) of California Civil Code Section
1798.80, including information about your gender or age range. This information
is collected directly from you in the context of being our consumer.
Ø We
collect your personal information for the following purposes:
l To
provide you with the Game, maintain your account, provide customer service,
process payments, provide push notifications of game events and updates, and
deliver voice and text chat and voice messages or otherwise facilitate
communications between users.
l To
process surveys.
l To
conduct events such as giveaways, draws and contests and similar events related
to the Game.
l To
improve our services, including the functionality of the Game.
l For
security and anti-cheating purposes, including to prevent and detect cheating
and other activities which may compromise the integrity of the Game.
l To
address and remediate technical issues and bugs.
l To
monitor our marketing initiatives.
l To
comply with our legal obligations and enforce our legal rights.
Ø We
disclose personal information to the following types of entities:
l Other
companies within our corporate group who process your personal information in
order to operate the Game.
l Other
companies that provide services on our behalf in support of the Game and who
are prohibited by contract from retaining, using, or disclosing personal
information for any purpose other than for providing their services to us.
l Regulators,
judicial authorities and law enforcement agencies
l Entities
that acquire all or substantially all of our business.
14.
EUROPE
This section applies to residents in Europe
covered by the General Data Protection Regulation (GDPR). If you wish
your data to be deleted, please contact us via our Support Email Address [help@fowgames.com].
1) Right to Object:
Ø While the processing of your personal
data is based on legitimate interests according to Article 6(1)(f) of the GDPR
and/or Section 2 of this Privacy Policy or any other applicable laws and
regulations in your country of residence, you have the right to object to our
processing. If you object, we will no longer process your personal data unless
there are compelling and prevailing legitimate grounds of processing as
described in Article 21 of the GDPR or any other applicable laws and
regulations in your country of residence; in particular, if the data is
necessary for the establishment, exercise or defense of legal claims. You also
have the right to lodge a complaint at a supervisory authority.
2) Right to Restrict Processing:
Ø You have
the right to restrict the processing of your personal data under the conditions
set out in Article 18 of the GDPR or any other applicable laws and regulations
in your country of residence.
3) Right to
Portability of Personal Data:
Ø You have
the right to receive your personal data in a structured, commonly used and
machine-readable format and have the right to transmit those data to another
controller under the conditions set out in Article 20 of the GDPR or any other
applicable laws and regulations in your country of residence.
15. Duty of Notification
Any additions, deletions, or modifications to the Privacy Policy
will be announced through the official café and 'Notices' within the game at
least 7 days prior to the revision. Contents that are disadvantageous to
customers will be notified at least 30 days before the revision.
This policy will take effect on August 28, 2024.