Privacy Policy (Game and Website)
Last Updated:
26 March 2025
Thank you for using our products and services! We respect your concerns about privacy and appreciate your
trust and confidence in us.
Please note that this privacy policy (“Privacy Policy”) only applies to the game Chasing Kaleidorider (the “Service”) and its official website (the “Website”). If you use any other products or services, please refer to the privacy policy for that particular product or service. to
If you have any questions about anything in this Privacy Policy, or want to exercise any rights
you may have, please contact us.
For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited.
SUMMARY
Here is a summary of the information contained in this Privacy Policy. You can find more detail
by clicking ‘More Information
’.
|
What information do we need to be able to provide the Service?
|
· If you use the Website to sign up for the Service, we
may collect certain information from you, such as your email address, and feedback information you
choose to provide.
· If you log in to use the Service, we will need some
information from you to set this up. This includes your email address and Google Play Account. Depending
on your use of the Service and the jurisdiction where you are based, you may also need to provide some
additional information to help us set up your account.
· To maintain the smooth operation of the Service, we will process device, game server, and crash and compliance information (such as device model, CPU information, device name, device type, device identifiers) If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns. |
|
|
How will we use your information?
|
· We use your information to allow you to sign up to and
log in to the Service, enable you to use the Service, notify you about the test qualifications of the
Service, identify the Service’s core users and users participating through advertising campaigns, locate
and resolve crash issues, and to comply with our legal obligations and enforce our legal
rights.
|
|
|
Who do we share your information with?
|
· All third party service providers providing services
for us are prohibited from retaining, using, or disclosing your personal information for any purpose
except where strictly necessary for the Service (i.e., to fulfil the purpose(s) described
above).
· In some cases we may be required by a court or be under
a legal obligation (such as a valid search warrant or subpoena) to disclose certain
information.
|
|
|
Where do we process your information?
|
· Pursuant to our contract with you, we may transfer data
outside of the location in which you are based for the purposes described in this Privacy
Policy.
· We have servers for the Website and Service in
Singapore.
.
We also have support, engineering and other
teams who may support the Service, including from Japan.
· In relation to the Website, for EEA/UK users, transfers
between our affiliates and to third parties use applicable safeguards, such as incorporating standard
contractual clauses, obtaining your consent first or taking into account adequacy
assessments.
|
|
|
How long do we keep your information?
|
· Unless otherwise required or permissible by applicable
laws, we retain your information for 90 days, or if you make a request, the for 30 days (except for Open
ID, which is retained for the lifetime of your use of the Service until you request for account
deletion, after which it is deleted within 90 days), or for so long as the information is needed to
fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then
delete or anonymise such data, in accordance with applicable laws.
|
|
|
How can I exercise my rights over my information?
|
· Certain jurisdictions offer users specific rights with
respect to their information, so you may have a right to access or receive a copy of your data, or to
delete your data or restrict or object to our processing of your data.
|
|
|
How will we notify you of changes?
|
· Changes to this Privacy Policy will be posted here. We
will also notify you of changes in accordance with relevant legal requirements.
|
Welcome to Chasing Kaleidorider!
This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in
connection with the game Chasing Kaleidorider (“Service
”) and its official website,
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 Website and Service. 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 Service. By using
the Service 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 Service is Proxima Beta Pte. Limited (“we
”, “
us
”, “
our
”).
If you have any questions about anything in this Privacy Policy, or want to exercise any rights
you may have, please contact us to reach out data protection officer. We have representatives for data protection purposes listed here.
We use cookies and other similar technologies (“Cookies
”) to enhance your experience using the Website. Cookies are small files which, when placed
on your device, enable us to provide certain features and functionalities. For more information about our
Cookies policy, click
here.
Children must not use the Website or Service for any purpose, except where their parent or
guardian has provided lawful consent (to the extent this option is available in your jurisdiction).
By children, we mean users under the age of 18 years old; or in the case of a region where the
minimum age for processing personal information differs, such different age. For users located in certain
regions we have listed the relevant minimum age as of the date of this policy in the table below. You should in
any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum
age.
Other than as provided above, we do not knowingly collect personal information from children
under these ages for any purpose. If you believe that we have personal information of a child under these ages
without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please
contact us.
Please note that the Website is available globally, but the Service is only available in
certain jurisdictions.
|
Region in which the user is located
|
Minimum age of the user
|
|
Algeria
|
19
|
|
Argentina
|
13
|
|
Australia
|
18
|
|
Bangladesh
|
18
|
|
Brazil
|
18
|
|
Cambodia
|
18
|
|
Canada
|
13
|
|
Colombia
|
18
|
|
Egypt
|
18
|
|
European Economic
Area
|
16
|
|
Hong Kong
|
18
|
|
Indonesia
|
21
|
|
Japan
|
18
|
|
Kazakhstan
|
18
|
|
Kuwait
|
21
|
|
Macau
|
18
|
|
Malaysia
|
18
|
|
Mexico
|
18
|
|
Morocco
|
18
|
|
Myanmar
|
18
|
|
New Zealand
|
16
|
|
Nigeria
|
13
|
|
Philippines
|
18
|
|
Qatar
|
18
|
|
Republic of Korea
|
14
|
|
Saudi Arabia
|
18
|
|
Serbia
|
15
|
|
Singapore
|
13
|
|
South Africa
|
18
|
|
Sri Lanka
|
18
|
|
Switzerland
|
14
|
|
Thailand
|
20
|
|
Tunisia
|
18
|
|
Türkiye
|
18
|
|
United Arab Emirates
|
21
|
|
United Kingdom
|
13
|
|
United States
|
13
|
This section provides more detail on the types of personal information we collect from you, and
why.
If you are in a jurisdiction in which a legal basis is required for the processing of your
personal information, it also identifies the legal basis under which we process your data.
|
Personal Information
|
Use
|
Legal Basis
|
|
Information you provide to us (either directly or through a third
party)
|
||
|
For the Website
|
||
|
Email
address
|
With
your consent, we use this information to send you news, events and promotions related to the Service, as
well as CBT invitations.
|
We
collect and use this information with your consent.
|
|
Survey
information (optional): Email, country or region of residence, and gaming habits and preferences, and
any other responses you choose to provide
|
With
your consent, we use user feedback information to improve the Service.
|
We
collect and use this information with your consent.
|
|
For the Service
|
||
|
Account Information: Email
address, Google Play account
|
We use
this information to allow you to log in to the Service and receive notifications about your
qualification to join the Service.
|
Necessary to perform our contract with you to provide
the Service.
|
|
Compliance Information: IP
address
|
We use this information to detect your
location and to provide you with the relevant content specific to your region to ensure compliance with
our legal obligations.
|
It is in our legitimate interest to
ensure compliance with applicable age-gating rules.
|
|
Survey Information: Your
questionnaire responses regarding your availability to participate in tests within a certain period, age
or age range, gender, and user experience with similar types of products
|
We use this information to identify
the Service’s core users and to better understand our users.
|
We collect and use this information
with your consent.
|
|
Customer Support Information:
Email address, screenshots, nickname,
open ID, country, social media account, device information, game data, log data.
|
We use this information to review and
respond to your concerns, improve our Services and provide troubleshooting, such as addressing and
remediating technical issues and bugs.
|
Necessary to perform our contract with
you to provide and support the Service.
|
|
Information generated as part of the Service
|
||
|
|
||
|
Device Information: Device
model, CPU information, device name, device type
|
We use this information to determine if users have compatible devices for the
Service.
|
Necessary to perform our contract with you to provide the Service.
|
|
Game Server Information:User
ID, nickname, profile picture, user token, Open ID
|
We use this information to link your Service data with your account to allow you to select your
corresponding server list.
|
Necessary to perform our contract with you to provide the Service.
|
|
Advertising Information: Advertising identifiers (Android ID and Appsflyer
ID)
|
We use this information to identify whether you have participated in the Service through
advertising campaigns.
|
It is in our legitimate interest to understand the effectiveness of our advertising
campaigns.
|
|
Crash Information: Crash or
error logs
|
We use this information to locate and resolve crash issues and to improve the
Service.
|
It is in our legitimate interest to use this information to ensure the security and integrity
of the Service.
|
We have servers for the Website and Service are located in Singapore. We also have support,
engineering and other teams who may support the Website and Service, including from Japan and other
regions.
Only where necessary will we share your personal information with third parties. Situations where this occur
are:
· Companies within our corporate groupwho process your personal information solely for the purpose of providing the Service to you.
All such group companies may only use your personal information in accordance with this Privacy Policy.
· Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you,
such as to comply with legal obligations or processes. In complying with the terms of valid legal processes,
such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in
advance of such disclosure.
· Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
o enforce our terms and conditions and other agreements, including investigation of any potential
violation thereof;
o detect, prevent or otherwise address security, fraud or technical issues; or
o protect the rights, property or safety of us, our users, a third party or the public as
required or permitted by law (such as exchanging information with other companies and organisations for the
purposes of fraud protection and credit risk reduction).
· A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer,
merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture
with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other
third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case
the information we hold about you may be sold as part of those assets and may be transferred to any prospective
buyer, new owner, or other third party involved in such sale or transfer.
We have information security and access policies that limit access to our systems and
technology, and we protect data through the use of technological protection measures such as
encryption.
Unfortunately, the transmission of information via the internet is not completely secure.
Although we will implement and maintain reasonable measures to protect your personal information, we cannot
guarantee the security of the information transmitted through the Service or otherwise via the Internet; any
transmission is at your own risk.
We do not keep your data for longer than is necessary to fulfil the relevant purpose described
above unless we are required or permitted to do so under law. If we retain your information
beyond the retention periods set out below, for example to comply with applicable laws, we will store it
separately from other types of personal information.
|
Personal Information
|
Retention Policy
|
|
For the Website
|
|
|
Email
address
Survey information
|
Stored for 90
days from collection or deleted within 30 working days of your request if you request for
deletion.
|
|
For the Service
|
|
|
Account
Information
Compliance
Information
Survey
Information
Customer
Support Information
Device
InformationGame Server Information
Advertising
Information
Crash
Information
|
Stored for 90 days from collection or
deleted within 30 working days of your request if you request for deletion.
Open ID will be stored for the
lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and
then deleted within 90 days.
|
Some jurisdictions’ laws grant specific rights to users of
the Service. Please refer to the Supplemental Jurisdiction-Specific
Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons
subject to data protection laws in the listed jurisdictions and how these can be exercised.
You may have certain rights in relation to the personal information we hold about you. Some of
these only apply in certain circumstances (as set out in more detail below). You can exercise some of these
rights directly by accessing and updating the information in your account. If you believe we hold any other
personal information about you, please contact us.
Access
You may have the right to access personal information we hold about you, how we use it, and who
we share it with.
Correction
You may have the right to correct personal information we hold that is inaccurate.
Erasure
You may be able to delete your account, or remove certain personal information, by sending us a
request by email. We may need to retain personal information if there are valid grounds under data protection
laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you
know if that is the case. Where you have requested that we erase personal information that has been made
available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell
others that are displaying the personal information or providing links to the personal information to erase it
too.
Restriction of Processing to Storage Only
You may have a right to require that we stop processing the personal information we hold about
you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing
the personal information, we may use it again if there are valid grounds under data protection laws for us to do
so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing
the personal information, we will take steps to tell any third party to whom we have disclosed the relevant
personal information so that they can stop processing it too.
Objection
You may have the right to object to our processing of your personal
information. If you wish to do so, please contact us .
Consent Withdrawal
To the extent provided by applicable laws and regulations, you may withdraw consent you
previously provided to us for certain processing activities by contacting us. Where consent is required to process your personal information, if you do not consent to the
processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that
the right to withdraw consent is only available if the legal basis for processing information is
consent.
Announcements
We may from time to time send you announcements when we consider it necessary to do so (for
example, when we temporarily suspend access to the Service for maintenance, or security, privacy or
administrative-related communications). These are essential system and service-related announcements and you are
not able to opt-out of these notifications, which are not promotional in nature.
To reach us for any data privacy related requests and questions, please refer to the following
contact information:
Email: dpo_kaleido@proximabeta.com
We will endeavour to deal with your request as soon as possible. This is without prejudice to
any right you may have to launch a claim with a data protection authority in the region in which you live or
work where you think we have infringed data protection laws.
If we make any changes to this Privacy Policy we will post the updated Privacy Policy here.
Please check this page frequently to see if there are any updates or changes to this Privacy Policy.
Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between
the English version and local language version of this Privacy Policy, the English version shall
prevail.
|
Jurisdiction
|
Representative
|
Address
|
Contact details
|
|
EU
|
Proxima Beta Europe
B.V.
|
Buitenveldertselaan
1-5, 1082 VA, Amsterdam, the Netherlands
|
|
|
UK
|
Image Frame Investment (UK)
Limited
|
Suite 1,
4th Floor, 80 Strand, London
,
United Kingdom WC2R 0RL
|
|
|
Republic of Korea
|
Kite Bird Korea Yuhan
Hoesa
|
25F, 55,
Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea
|
|
|
Serbia
|
Karanovic & Partners
o.a.d. Beograd
|
Resavska 23,
Belgrade, 11000, Serbia
|
local.representative@karanovicpartners.com
|
|
Thailand
|
Tencent (Thailand)
Company Limited
|
8 T-One Building,
Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong
Toei, Bangkok 10110, Thailand
|
|
|
Türkiye
|
Özdağıstanli Ekici
Avukatlık Ortaklığı.
|
Nidakule Ataşehir
Kuzey, Begonya Sok. No:3 Kat. 17 D: 162 / 34746 Ataşehir / İstanbul, Türkiye
Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority
is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698.
Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-Service
conduct, suspensions, investigations, civil or criminal complaints.
|
SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS
Some jurisdictions’ laws contain additional terms for users of the Website and
Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the
terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our
Privacy Policy above.
Algeria
By using the Website, you give your consent to the collection, storage, treatment and use of your
personal information, and transfer of your personal information to third parties or our affiliates to help us
deliver the Website, in each case location in the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).
Argentina
If you are dissatisfied with our response to your request for access to, correction, or erasure
of your personal information or your privacy complaint in respect of your personal information, you may contact
the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos
Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar). While we take reasonable steps to ensure that third party recipients of your personal
information comply with privacy laws that are similar to those of your jurisdiction, by providing your personal information and by using the Website, you consent to the transfer of your
personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws
that may apply in Argentina.
We take reasonable steps to ensure that third party recipients of your personal information
located outside Australia handle your personal information in a manner that is consistent with Australian
privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions
of these third party recipients. You have the right to access personal information we hold about you, how we use
it, and who we share it with. You have the right to correct any of your personal information we hold that is
inaccurate.
If you are under the age of 18, you undertake that you have the consent of your parent or legal
guardian to use the Website.
Where practicable, we will give you the option of not identifying yourself or using a pseudonym
when using the Website. You acknowledge that if you do not provide us with your personal information, we may be
unable to provide you with access to certain features or sections of the Website, including social media
integration and in-Website purchases.
If you are dissatisfied with our response to your request for access to, or correction of, your
personal information or your privacy complaint in respect of your personal information, you may contact the
Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).
Bangladesh
By acknowledging the Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal
data, including disclosing to third parties, to the extent provided by the Privacy Policy. You also consent to the cross-border transfer of your information to any country where we
have databases or affiliates and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).
Brazil
Whenever we use your personal information based on your consent, you may
revoke the consent that you have previously given for the collection, use and disclosure of your personal
information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account
or you can contact us as set out in Section 8 (Contact). This may affect our provision of the Website to you.
BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO
COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE
EXTENT PROVIDED BY THIS PRIVACY POLICY
Canada
If you are located in Canada and wish to obtain written information about our policies and
practices with respect to our service providers located outside Canada, you may contact us as specified in Section 8 (Contact). Where we use service providers who might have access to your personal information, we require
them to have privacy and security standards that are comparable to ours. We use contracts and other measures
with our service providers to maintain the confidentiality and security of your personal information and to
prevent it from being used for any purpose other than as provided in this Privacy Policy.
Colombia
Your authorization to process personal information for the Website may be expressed (i) in
writing, (ii) orally or (iii) through unequivocal conduct that allows us to reasonably conclude that your
authorization has been granted, such as the act of accepting the Privacy Policy. We may keep evidence of said
authorizations, while respecting the principles of confidentiality and privacy of information.
As a data subject you have certain rights, including (i) to access, update and rectify your
personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have
processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke
the consent you have given us to process your personal data, unless the processing is based on compelling
legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right
to erasure); and (vii) to freely access your information. You can contact us to exercise any of these rights,
using the information specified in Section 8 (Contact)
Egypt
By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have
read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing,
storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in
which we have databases or affiliates, in particular to to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).
You also acknowledge your consent to receiving marketing messages from us, whether through
e-mails or pop-ups or other such means.
If you are a new user, you have seven days to inform us of any objection you may have to this
Privacy Policy.
As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.
France
Instructions for the processing of your personal data after your death.
You have the right to provide us with general or specific instructions for the
retention, deletion, and communication of your personal data after your death. The specific instructions are
only valid for the processing activities mentioned therein and the processing of these instructions is subject
to your specific consent. You may amend or revoke your instructions at any time.
You may designate a person responsible for the implementation of
your instructions. This person will be informed of your instructions in the event of your death, and be entitled
to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the
event of the death of the designated person, their heirs will have the right to be informed of your instructions
and to request their implementation from us.
When you wish to make such instructions, please contact us
as set out in Section 8 (Contact).
Hong Kong
As a Hong Kong data subject, you have legal rights in relation to the personal information we
hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a
subject access request to receive a copy of the data we process about you, a data correction request as well as
a right to object to the use of your personal data for direct marketing purposes (where applicable). A fee may
be chargeable by us for complying with a data access request.
Where we permit any third parties to collect and use sensitive personal
information, we shall use reasonable measures to ensure that the third parties do not further disclose such
information to the extent required by applicable laws.
To the extent provided by applicable laws and regulations, you may withdraw
any consent you previously provided to us for certain processing activities by contacting us as set out in Section 8 (Contact). Where consent is required to process your personal information, if you do
not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected
service. Where the processing of your personal data is not based on consent, our
processing is based on certain legitimate uses as permitted under law and in compliance with applicable
law.
Indonesia
By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with
this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access
to our services.
If you are under the age of 18, you undertake that you have the consent of your parent or legal
guardian to use the Website.
In the event we fail to maintain the confidentiality of your personal information in the
Website, we will notify you through the contact information provided by you, to the extent required by local
laws and regulations.
You are responsible for making sure that any personal details which you provide to us are
accurate and current. In order to confirm the accuracy of the information, we may also verify the information
provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before
providing us with any other person’s personal information (for example, for referral promotions), in which case
we will always assume that you have already obtained prior consent, and as such, you will be responsible for any
claims whatsoever from any party arising as a result of the absence of such consent(s).
If you are under the age of 18, you must obtain your parent’s or legal guardian’s consent to
use the Website.
By clicking “accept”, you consent to the transfer of your personal information to third parties
(if any), which may include the cross-border transfer of your information to any country where we have databases
or affiliates and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).
The categories of personal information specified in to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information) may include "special care-required personal information" (i.e., sensitive information as
detailed under applicable law), and you consent to the collection of such information.
You may request us to notify you about the purposes of use of, to disclose, to make any
correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information
which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan.
When you wish to make such requests, please contact us as set out in Section 8 (Contact).
Kazakhstan
If you are under the age of 18, you must obtain your parent’s or legal guardian’s consent to
use the Website.
By clicking “accept”, you consent to the collection, use, disclosure, transfer, export (to the
extent permitted by applicable laws), sharing and storage of your personal information as described in this
Privacy Policy. The transfer of your personal information to third parties, which may include the cross-border
transfer of your information to any country where we have databases or affiliates and, in particular, to
Singapore and Japan.
In the event of any discrepancy or inconsistency between the English version and the Kazakh
version of this Privacy Policy, the Kazakh version shall prevail.
Your Rights
· Right of access: You have the right to request access to and obtain a copy of the personal information we
have process about you or that is being processed on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the
amounts as permitted under law.
When handling a data access request, we are permitted to request for certain information to
verify the identity of the requester to ensure that he/she is the person legally entitled to make the data
access request.
· Right to correction: You may request for the correction of your personal information or delete such personal
information if it is impossible to correct it. When handling a data correction request, we are permitted to
request for certain information to verify the identity of the requester to ensure that he/she is the person
legally entitled to make the data correction request.
· Right to blocking / de-blocking: You have the right to request the blocking of personal information related you, if you become
aware of a violation regarding the collection and processing your data. If the violation has not been proved,
you may request to de-block your data.
· Right to deletion: You have the right to request deletion of your personal data if the collection and processing
of your data has been conducted in violation of Kazakh laws.
· Processing of your personal information in public sources of personal
data: You may request to limit or provide your consent on the processing of your personal
information in public sources of personal data.
Kingdom of Saudi Arabia
You consent to the collection, use, disclosure, transfer, export (to the
extent permitted by applicable laws) and storage of your personal information as described in this Privacy
Policy including (without limitation) for the purposes of showing you personalised advertising when you use the
services.
Kuwait
By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and
process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in
line with the provisions of this Privacy Policy.
You have the right not to provide your personal information. However, as a result, we may not
be able to provide the Website and Service to you. As a Macau data subject you have legal rights in relation to
your personal information (to the extent permitted under applicable laws and regulations). You are entitled to
make a subject access request to request a copy of the data we process about you, to make a data correction
request, and have the right to oppose the use of your personal information for marketing or any other form of
commercial prospecting (where applicable), or on any grounds of personal nature. A fee may be chargeable by us
for complying with a data access request.
Malaysia
Right of access: You have the right to request access to and obtain a copy of your personal information
that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the
amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to
verify the identity of the requester to ensure that he/she is the person legally entitled to make the data
access request.
Right of correction: You may request for the correction of your personal information. When handling a data
correction request, we are permitted to request for certain information to verify the identity of the requester
to ensure that he/she is the person legally entitled to make the data correction request.
Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details
provided above. However, this may affect our provision of the Website and Service to you.
To protect your personal information and handle complaints relating to your personal information, we have appointed our data protection officer, responsible for the management and safety of
your personal information. Please see our data protection officer’s email as set out in Section 7 (Contact).
Mexico
Some of the purposes of processing specified in Section 3 (How We Process Your Personal Information) are voluntary, which may include to show you personalised recommendations or advertising. We
may also use your personal data for the voluntary purpose of sending information to your email that we may
consider relevant to you.
In general, we do not require your consent to carry out the transfers detailed in
Section 4 (How We Store and Share Your Personal Information). In any case, by using the Website and providing us with your personal data, you agree to the
data transfers detailed therein that require your consent.
To understand more about and exercise your rights to “Access”, “Correction”, “Erasure”,
“Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and
disclosure of your personal data, and “Advertising” as well as the applicable means, procedures and requirements
to exercise any of your rights, please contact us as specified in Section 8 (Contact).
Morocco
We collect information for purposes strictly necessary for the
proper use of the Website. By accepting this Privacy Policy, you explicitly accept that your personal data may
be subject to processing by the Website.
Kindly note:
· the identity of the Data Controller is set out at the beginning of this Privacy Policy
· the purposes of processing personal data are set out in Section 3 (How We Process Your Personal Information)
· recipients or categories of recipients are set out in Section 4 (How We Store and Share Your Personal Information)
· whether the answer to the questions is compulsory or optional, as well as the
possible consequences of a lack of answer: please refer to Section 3 (How We Process Your Personal Information) and Section 7 (Your Rights)
New Zealand
We take reasonable steps to ensure that third party recipients of
your personal information located outside New Zealand handle your personal information in a manner that is
consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability
for, the acts and omissions of these third party recipients.
You have the right to access personal information we hold about
you, how we use it, and who we share it with. You have the right to request the correction of any of your
personal information we hold that is inaccurate.
If you are under the age of 16, you undertake that you have the
consent of your parent or legal guardian to use the Website.
If you are dissatisfied with our response to your request for
access to, or correction of, your personal information or your privacy complaint in respect of your personal
information, you may contact the Office of the New Zealand Privacy Commissioner
(www.privacy.org.nz).
While we take reasonable steps to ensure that third party
recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction,
you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee
that they will comply with those privacy laws.
Peru
You may exercise rights related to the protection of personal
information by requesting access to your personal information or the correction, deletion or suspension of
processing of your personal information, pursuant to the Personal Data Protection Law (the “Law
”). You may also exercise these rights through your legal guardian or someone who has been
authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in
accordance with the Law.
You can also withdraw your consent or demand a suspension of the
personal information processing at any time.
If you consider that your request has not been met you may file a
claim with the Peruvian National Authority of Personal Data Protection.
To protect your personal information and handle complaints relating
to your personal information, we have appointed the following department responsible for managing and protecting
your personal information.
· Data Protection Team, responsible for the management and safety of
your personal information
· Contact: as set out in Section 8 (Contact)
Philippines
You are entitled to the following rights:
· Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is
being, or has been processed, including the existence of automated decision-making and profiling.
· Right to object. You may in certain circumstances have the right to object to the processing of your personal information,
including processing for direct marketing, automated processing or profiling.
· Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal
information.
· Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal
information and have us correct it, unless the request is vexatious or otherwise unreasonable.
· Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or
destruction of your personal information.
By consenting to this Privacy Policy, you consent to us:
· collecting and processing your personal information as described in Section 3 (How We Process Your Personal Information);
· sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described
in this Privacy Policy and for the purposes stated herein; and
· transferring or storing your personal information in destinations outside the Philippines as described in
Section 4 (How We Store and Share Your Personal Information)
Qatar
If you are using the Website in Qatar, you consent (for the purposes of Law
No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your
information in accordance with this Privacy Policy.
Republic of Korea
For the performance of the services detailed in this Privacy Policy, we delegate the processing of your personal information to the following professional service providers:
|
Delegatee
|
Description of Delegated Services
|
|
Tencent Cloud
|
Data processor: Processes and stores data on behalf of
the data controller for personal information in relation to the Website
|
Overseas Transfer of Personal Information
We transfer personal information to third parties overseas as
follows:
|
Recipient (Contact Information of Information Manager)
|
Country to which Your Personal Information is to be Transferred
|
Date and Method of Transfer
|
Types of Your Personal Information to be Transferred
|
Purposes of Use by Recipients
|
Period of Retention of Use by Recipient
|
|
Tencent Cloud LLC |
Singapore
Japan
|
Transmitted through from time to time at the time of
providing the Website
|
Personal information for the Website
|
Storage of personal information
|
For the data retention period specified under
“How We Store and Share Your Personal Information
”
|
Data Destruction
Personal information is retained in accordance with the data retention
periods as detailed in section
“Data Retention”.
With the exception of the personal information set out below,
personal information, which has fulfilled the purpose for which it was collected or used,
and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information
stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed
information will be destroyed by shredding or incinerating such information.
The personal information detailed in section
“Data Retention”
are required to be retained pursuant to the following laws:
|
Act on the Consumer Protection in Electronic Commerce, Etc.
|
Article 6 of the Act on the Consumer Protection in Electronic Commerce
|
In an electronic commerce or a mail-order sale:
· Records regarding labelling and advertising (6 months)
· Records regarding execution or withdrawal of a contract (5 years)
· Records regarding the payment of a price and the supply of goods and services (5
years)
· Records regarding customer services or dispute resolution (3 years)
|
|
Protection of Communications Secrets Act
|
Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications
Secrets Act
|
· Log records, IP address (3 months)
· The date of telecommunications by users, the time that the telecommunications start and
end, the frequency of use (12 months)
|
You may exercise rights related to the protection of personal information by requesting
access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to
applicable laws such as the Personal Information Protection Act (“PIPA
”). You may also exercise these rights through your legal guardian or someone who has been
authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in
accordance with the Enforcement Regulations of the PIPA. You can also withdraw your consent or demand a
suspension of the personal information processing at any time.
Additional Use and Provision of Personal Information
In accordance with the PIPA, we may use or provide personal information within the scope of
reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been
caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc. We
will determine with due care whether to use or provide personal information in consideration of general
circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal
information, how personal information will be used or provided, items of personal information to be used or
provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects,
impact on data subjects upon the use or provision, and measures taken to protect subject information. Specific
considerations are as follows:
· whether the additional use/provision is related to the initial purpose of the
collection;
· whether the additional use/provision is foreseeable in light of the circumstances under
which personal information was collected and practices regarding processing;
· whether the additional use/provision unfairly infringe on the interests of the data
subject; and
· whether the necessary security measures such as pseudonymization or encryption were
taken.
Domestic Privacy Representative
Pursuant to the Article 32-5 of Network Act and Article 39-11 of the amended PIPA, the
information regarding the domestic agent is as follows:
· Name: Kite Bird Korea Yuhan Hoesa
· Address: 25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro
2-ga), Korea
· Telephone: +82-2-2185-0926
· Email: specified in Section 8 (Contact)
Contact
To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your
personal information.
· Data Protection Department, responsible for the management and safety of
your personal information
· Telephone: +82-2-2185-0926
· Email: specified in Section 8 (Contact)
Serbia
Our designated local representative in Serbia is Karanovic & Partners for the purposes of
compliance with the Law on Personal Data Protection, and can be contacted at
local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your
email.
· Name: Karanovic & Partners o.a.d. Beograd
· Address: Resavska 23, Belgrade, 11000, Serbia
· Telephone Number: +381 11 3094 200
· E-mail: local.representative@karanovicpartners.com
Singapore
By accepting this Privacy Policy, you consent to the collection, use and disclosure of personal
data as set out in this Privacy Policy, including cross-border transfer of your information to any country or
region where we have databases or affiliates and, in particular, the locations specified in in Section 4 (How We Store and Share Your Personal Information).In situations where consent is not obtained, Sixjoy Limited collects, uses, or discloses personal data in
accordance with an exception under the Personal Data Protection Act 2012 or as required or authorized by
any other applicable law.
You have the right to access your personal information, how we use it, and who we share it
with. You have the right to correct any of your personal information that is inaccurate.
Our designated data protection officer for the purposes of compliance with the Personal Data
Protection Act 2012 can be contacted here.
South Africa
You have the right to lodge a complaint with the Information Regulator (South Africa) by
emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd
Floor Braampark, Braamfontein, Johannesburg, South Africa.
Sri Lanka
By clicking “accept”, you consent to the Privacy Policy and permit the collection, use and
disclosure of your personal information. However, if you are under the age of 18, you undertake that you have
the consent of your parent or legal guardian to use the Website.
Personalised Marketing
By clicking “accept”, you hereby consent to being shown personalised advertisements. You may
choose to stop receiving personalised advertising from us by contacting us at Section 8 (Contact).
Taiwan
We do not knowingly collect or solicit personal information from anyone under the age of 7 or
knowingly allow such persons to use the Website platform. If you are under 7 years of age, please do not attempt
to use our Website or send any personal information about yourself to us. No one under the age of 7 may provide
any personal information to us while using the Website. In the case of users located in Taiwan, persons under
the age of 20 are required to obtain parental/guardian consent prior to using the Website.
Thailand
By clicking "accept", you acknowledge that you have read, understood, and
agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the
Website.
If you are under the age of 20, you undertake that you have obtained your
parent or legal guardian’s consent to use the Website.
To the extent provided for by the Thai Personal Data Protection Act (PDPA),
you may:
· withdraw your consent to the processing of your personal data (only where the
legal basis for our processing is consent); however, please note that where consent is required to process your
personal data, we may not be able to deliver the expected service without it;
· request us to provide you access to, make any correction to, cease any
automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase
your personal data;
· request us to provide you or a third party with your personal data which is
stored by us in a machine readable format; and/or
· lodge a complaint to a relevant authority.
Where you wish to make such requests, please contact us as set out in Section 8 (Contact).
The contact details of our designated local representative in Thailand for the
purposes of compliance with the PDPA is as set out in Section 8 (Contact) and can be contacted via email. Please include the word “Thailand” in the subject
line of your email.
Türkiye
You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish
data subject, you may have the right to apply to the data controller and (to the extent permitted under
applicable laws and regulations):
· learn whether or not your personal data has been processed;
· request information about processing if your personal data has been
processed;
· learn the purpose of processing of your personal data and whether they have
been used accordingly;
· know the third parties in the country or abroad to whom personal data has been
transferred;
· request rectification in the event personal data is incomplete or inaccurate
and to demand the operations in this regard be reported to third parties your personal data has been transferred
to;
· request deletion or destruction of personal data within the framework of the
conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third
parties your personal data has been transferred to;
· object the occurrence of any consequence that is to your detriment by means of
analysis of personal data solely through automated systems; and
· demand compensation for the damages that you have suffered as a result of
unlawful processing of your personal data.
In accordance with Article 9 of the DPL, your personal data may be transferred
abroad as follows:
|
Identity of the overseas recipient
|
Location of the recipient (or as otherwise stated in the
recipient’s privacy policy)
|
Purposes of use of Personal Information by the
recipient
|
Items of Personal Information to be provided
|
|
Tencent Cloud LLC
|
Singapore
Japan
|
Storage of personal information for the Website
|
Personal information for the Website
|
Ukraine
By accepting this Privacy Policy, you expressly authorize us to collect, use,
store, and process your personal data, including disclosing to third parties and transferring to countries or
regions other than Ukraine, to the extent and for the purposes provided in this Privacy Policy.
United Arab Emirates
You consent to the collection, use, disclosure, transfer, export (to the
extent permitted by applicable laws), sharing and storage of your personal information, as described in the
Privacy Policy, including (without limitation) for the purposes of showing you personalised advertising when you
use the Website.
We may voluntarily report a cyber-security incident where it constitutes a
crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant
authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident
can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation
that provides a process for logging incidents and advising on known cyber security threats in the
UAE.
United States
For purposes of this section, “personal information” and “sensitive personal information” have
the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights
Act of 2020) (“CCPA
”), and respectively include the terms “personal data” and “sensitive data” as defined in
the Colorado Privacy Act (“
CPA
”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“
CTDPA
”), the Utah Consumer Privacy Act (“
UCPA
”) and the Virginia Consumer Data Protection Act (“
VCDPA
”), (collectively, “
US State Laws
”). The terms do not include information excluded from the scope of US State Laws.
Collection and Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed for a business
purpose the following categories of personal information, including sensitive personal information (denoted by *), from or about you or your device:
· Identifiers, such as your email address and any other information you choose
to provide in the surveys. This information is collected directly from you if you choose to provide
it.
· Characteristics of protected classifications under California or federal law
such as national origin, gender, or age if you choose to provide it in a survey. This information is collected
directly from you in the context of being our consumer.
· Professional or employment-related information such as your profession if you
choose to provide it in a survey. This information is collected directly from you.
We collect and disclose your personal information, including sensitive personal information,
for the following purposes:
· to provide you with the Website and allow you to sign up for the Service;
· to send you news, events and promotions relating to the Service, as well as
CBT invitations;
· to process surveys; and
· to improve the Service.
For additional information about what each type of personal information is
used for, see Section 3 (How We Process Your Personal Information).
We disclose each of the categories of personal information that we collect as described
in Section 4 (How We Store and Share Your Personal Information).
In the past 12 months, we have not sold or shared personal information of California residents
within the meaning of “sold” and “share” in the CCPA And we have no knowledge of any sale or sharing of
personal information of users under 16 years of age.
In addition, we do not use or disclose sensitive personal information for purposes other than
to perform the services reasonably expected by an average consumer who requests those services or as
otherwise permitted by US State Laws.
Retention of Your Personal Information
The retention period varies among the different categories of data collected.
For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.
Rights under US State Laws:
Depending on where you live, you may have some or all of the rights listed below in relation to
information that we have collected about you. However, these rights are not absolute, and in certain cases, we
may decline your request as permitted by law.
· Right to Access/Know. equest we confirm whether we process information about you and give you access to that
information. You may also request to receive that information in a portable and, to the extent technically
feasible, readily usable format that allows you to transmit the information to another business without
impediment. If you are a California resident, you may request the following information about our collection,
use and disclosure of your information:
o the categories of personal information about you that we collected;
o the categories of sources from which the personal information was collected;
o the business or commercial purposes for collecting personal information about you;
o the categories of third parties to whom we disclosed personal information about you and the
categories of personal information that was disclosed (if applicable) and the purpose for disclosing the
personal information about you; and
o the specific pieces of personal information we collected about you;
· Request to Delete. Request we delete personal information we collected about you;
· Request to Correct. Request we correct inaccurate personal information that we maintain about you;
· Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted
advertising or the profiling of your information in furtherance of decisions that produce legal or similarly
significant effects; and
· Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different
level or quality of services or denying goods or services to you when you exercise your rights under the US
State Laws.
How to Exercise Your Rights
First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data by
contacting us as specified in Section 8 (Contact). We may take steps to verify your identity before complying with your request
to protect your privacy and security, and may decline your request if we are unable to verify your identity. To
verify your identity, we may need the following information from you: your first name, last name, address, phone
number, date of birth and email address.
Depending on where you live, you may exercise these rights yourself or you may also designate an
authorized agent to make these requests on your behalf. In order for us to process the request, you must provide
the authorized agent with signed written permission. We reserve the request to require the agent to verify their
own identity and to confirm directly with you that you have provided the authorized agent permission to submit
the request.
In addition, where applicable, we will provide you with more information about
our appeal process. When you submit a request or launch an appeal, we will limit our collection of your
information to only what is necessary to securely fulfil your request or process your appeal. We will not
require you or your authorized agent to pay a fee for the verification of your request or appeal.
Questions
If you have questions or concerns regarding this Privacy Policy, please
contact us as set out in Section 8 (Contact).
Vietnam
By accepting this Privacy Policy, you expressly agree and authorise us to
collect, use, store, and process your personal information, including, lawfully disclosing and transferring it
to third parties, as described in this Privacy Policy.
Where we permit any third parties to collect and use your personal
information, we shall take reasonable measures to ensure that the third parties do not further disclose the
personal information.
You have the right to access, correct, and erase the personal information we
hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process,
use and disclose your personal information and to request us to stop providing your personal information to a
third party.