PRIVACY POLICY

(For EEA and UK Residents)

(Effective Date: January 22th 2021)

1. Introduction

We take privacy seriously, and we are committed to protecting personal data (the “Personal Data”) of our users (“you” or “User”) who reside in the territory of the European Economic Area (EEA) which includes the European Union member states and Iceland, Liechtenstein, and Norway. This policy also covers our users who reside within the United Kingdom.

This Privacy Policy (the "Policy”) is based on the principles set forth under the General Data Protection Regulation (GDPR) (and any other applicable law mandating data protection/GDPR) and describes the full scope of purposes and reasons for collecting and processing of Personal Data. This privacy policy also determines and limits what Personal Data we collect and how we use it (several sections below), how long we store it (is covered in each section devoted to the specific data), who has access to it, and what rights and other control mechanisms are available to you as a User.

This Policy applies where we are acting as a data controller concerning your data and is limited to data collected or received by us through your use of our Services (defined hereinafter).  

2. Who We Are

Gravity Interactive Inc. ("Controller"), with Controller’s affiliates and independent contractors (“Co-Providers”, collectively with Controller, "us," "our," or, "we"), provide mobile game named Ragnarok MMORPG (“Game”) and related services, including, without limitation, online communities for Game or social network services offered by us via warpportal.com or our branded websites (“Sites”) (collectively, our “Service(s)”). For clarity, the specific list of Controller’s affiliates and Co Providers are as followed.

The Services for our Game includes Sites, without limitation, such as online communities for Game or social network services offered by us via warpportal.com or our branded websites. The specific list of our Sites are as followed.

The Personal Data is processed by:

Company Name: Gravity Interactive, Inc.

Official Address: 7001 Village Drive Buena Park, CA 90621, California

Phone: 714-736-3415

Contact Email: warpportalmobile@warpportal.com


The EU Representative of Controller under Art. 27 GDPR can be reached at:

Company Name: The DPO Centre (Europe) Ltd.

Official Address: Alexandra House, Ballsbridge Business Park, Ballsbridge Park, Merrion Road, Dublin, Ireland, DO4 C7H2

Phone: +353 1 631 9460

Contact Email: EURep@warpportal.com

Further, our data protection officer can be reached at:

Name : Martin Ok

Email : king@gravity.co.kr.

Address : Sangam-Dong, Nuritkum Square R&D Tower 15F, 396, World Cup buk-ro, Mapo-gu, Seoul, Korea ct name based on which the Personal Data is transferred are as followed.

3. Processing of Personal Data

We process your Personal Data when they are strictly necessary for the following purposes:

3.1 Performance of our Services

We process your Personal Data on the lawful basis of performance of the agreement concluded between you and us in order:

• to provide our Services to Users namely: registration (creation) and operation of Game account, providing access to the Game account, formation and performance of the agreement with us on using the Services, providing the Game, the Services and Game access to Users, sending, processing of and responding to support tickets along with other communications with us, payment acceptance;
• to enhance the security and safety of your Game accounts;
• to communicate with you about transactions made by you while using our Services or Game, as well as to send you notifications related to your account security such as notifications about password recovery requests, editing security settings, changing of e-mail or profile settings and similar;
• to send you information about updates in our Services or Game, about features on our Sites, about upcoming events (online and offline) and other information related to our Services or Game (in case you have not unsubscribed);
• to inform you about changes in our policies and legal documents;
• to communicate with you to resolve any problem you faced while using our Services or Game;
• to inform you about our activities (in case you have not unsubscribed); for developing new tools, products or services for you;
• to provide support, as well as technical support, including, but not limited to, Game and Services updates, product patches and fixes and other similar communications;
• to restore access to the User’s account, Services and/or to the Game;
• to restore lost payments made by the User to improve our Services and Game, as well as while requesting your feedback about our Services and Game;
• to provide you with information, Services, and the Game available at or intended for the territory where you are;
• to send notifications or communications related to access to Our Services and/or the Game, password restoring or otherwise restoring access to the User’s account. You can disable this feature at any time, though you will be unable to use such features.

For these purposes, we process the following Personal Data:

• Compulsory Data that is processed in all events:
  - User’s ID in the social network that is used for registration at Game (if applicable) 

  - correspondence with User, including support tickets along with other communications;

  - IP address and other online identifiers of User’s devices and applications
   

Compulsory Data is required for us to provide Services and the Game to Users and perform other obligations under the agreements concluded with Users. Request for erasing of such data may result in your inability of using our Services as set forth in below.

Compulsory Data may be collected through, namely:

• through registration with Services and/or with the Game;
• while contacting us via e-mail, phone or mailing address of ours;
• while contacting our support team or otherwise;
• while using the forum, chats related to Services and/or the Game;
• while using Services and/or the Game otherwise (including information you provide to when participating in competitions, contests, and tournaments or responding to surveys, e.g. your contact details);
   

We also process anonymous data to analyze and produce statistics related to the habits, usage patterns, as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates.

If we find that you provided incorrect or inaccurate Personal Data, it may restrict (ban) your Game account until you amend it.

3.2 Payment

When the User tops up his or her Game account or makes payments via application market such as Google Play or App Store (the “App Markets”), we and the App Markets that is chosen by the User to process the payment exchange with the following Data:

• user ID from our billing system
• user ID in the payment system
• payment (transaction/order) ID
• date and time of payment (transaction/order)
• amount of payment (transaction/order)
• the currency of payment (transaction/order)

When the User use credit cards for payment purposes, the Data required are:

• name of the cardholder;
• masked card number - 6 symbols and last 4 digits;
• country code (if applicable);
• address (if applicable).

Such Data regarding credit card payment as mentioned is provided by the User directly to the payment systems under the terms of use of such system that the system may require Users to enter before processing the payment. We do not process such Data.

3.3 Promotion

We process Personal Data on the lawful bases of consent and legitimate interests pursued by us or a third party (e.g., the interests of other customers of ours), except where such interests are overridden by your prevailing data protection rights and if you have withdrawn your consent, to send promotional or marketing information and news about the planned contests, promotions and similar events, news about our Services and the Game.

If you do not wish to receive such information, you can unsubscribe from receipt of such information following the instructions as described in the corresponding messages or Game account interface.

We also process Personal Data on the same lawful basis in order to manage Users’ relationships and organization, follow-up, communication, subscription and invitations relating to competitions, events or game tournaments organized or supported by us (for example, communication with you when you take part in online or offline competitions, events or game tournaments organized or supported by us or arrange your travel, receipt of gifts and awards, to which you may be entitled as a result of winning in online or offline competitions or events, etc.).

The scope and purpose of the processing of your Personal Data, among other conditions for the processing, is specified in this Policy. We will notify you about any changes in our Policy.

Process of Non-Personal Data for improvement and development

To provide quality Services and to justify your expectations of Our Services and/or Game, we collect anonymous data:

• name and version of the operating system,
• the size of RAM
• the size of available disk space
• parameters of the network channel and internet connection such as network bandwidth and delay from User’s computer to our servers, traceroute information between your PC and our servers, etc.
• other data that is mentioned in the Technical requirements to the Game

We collect information about your Game' preferences, progress in Game, playtime, as well as information about device settings, unique device identifiers, and crash data. We process and store such data also to evaluate development plans, provide updates to the Services and Game, bug-fixing.

Such information, is stored for the validity period of relevant agreements with us and 1 year after the termination of such agreements unless there is a legitimate reason for a longer processing.

Be also aware, that for the purpose of organization of game process, we collect information about your in-game activities, logs, and data on in-game transactions. Such data also used for Game violations detections (as well as Sites violations) to prevent or punish for cheating and unfair gaming behavior. This data is used for detection, investigation, prevention and, where applicable, and stored only for the minimum amount of time needed for this purpose. If the data indicates that a violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such violations. Also be aware that enjoying a certain User’s rights shall be in balance with rights and interests of other Users and should not affect the rights and freedoms of other parties.

3.4 Prevention of illegal behavior

We process your Personal Data on the lawful basis of compliance with legal obligations that we are subject to in order:

• to prevent the illegal use of our Services and the Game if there is reason to believe that there is a risk to security of Our Servers (i.e. blocking of concurrent IP addresses).
  For this purpose, the Data processed is:
  • IP address and other online identifiers, 
  • browser or device identifiers,
  • operating system,
  • crash data.
• to prevent illegal user’s access
  For this purpose, the Data processed is:
  • the organization of the game process,
  • information about your in-game character activities, logs, and data on in-game transactions,
  • Game data and commands the so-called log files (information on the actions made by the character in the Game generated by the software, fixed in symbolic non-personal form),
  • the content of in-game chats (correspondence).

We use this data for decisions to ban a Game account or user’s character, according to the rules of the relevant Game.

In the event of litigation between the User and us or in case we receive a request from competent authority, such data can be combined with the personal information you provide and are stored during the period of resolution of the dispute.

4. Security Measures

Our endeavors to implement technical and organizational measures to protect your Personal Data against accidental or unlawful destruction, alteration or loss, unauthorized disclosure, or access. We, affiliates and third parties authorized to access the Personal Data, are required to give the undertaking to maintain such confidentiality and secrecy.

Among other measures, any information sent to us is encrypted (scrambled) using high qualified technology. This is industry-standard encryption technology that protects your data while being sent over the Internet from being intercepted and misused by third parties.

We have put in place, and regularly reviews and updates, appropriate physical, electronic, and managerial procedures to keep the data safe and help prevent unauthorized access, maintain data security and correctly use the information collected.

Should we become aware of a data breach we will take all relevant actions and steps necessary to rectify the breach. We will also notify the relevant supervisory authority and individuals (if required under the GDPR and other applicable data protection laws) and work with other parties as required to ensure any breaches are remedied and there is no other compromise of personal data.

5. Sharing of User’s information

We do not transfer your data to anyone, except for those specified in this Policy or as provided by the rules into force. This is related to the provision of Our Services and performance of contracts you have concluded with us. If such transfer to third parties is related to any other purpose, we will notify you of such transfer.

We do not sell your personal information and does not receive benefits from any treatment of your data. We do not use your data for advertising or promotion of products and services of third parties.

(1) Regarding Payment systems, we share your Personal Data such as:

Email address, IP address, information about in-game purchases, and other information you provide to us for the purpose of fulfilling your purchase. The list of payment methods (payment systems, payment agents) that may be used by the User for payments and with which we may share your data are described at our Sites. The specific list of the entities who access the Personal Data to process the payment, the place where the transferred Personal Data is stored and the relevant contract name based on which the Personal Data is transferred are as followed.

(2) With data storage partners, we share your Personal Data

Some of the information is stored using third-party data storage services. We provide personal information to our affiliates and other trusted businesses or persons to process it for us, in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. The specific list of the entities whose information storage service is used for the custody of Personal Data, the place where the transferred Personal Data is stored and the relevant contract name based on which the Personal Data is transferred are as followed.

The data is stored separately. Your data may be combined with other data collected by us in exceptional cases, for example, in case of a violation by users of the agreement with us or the rules of the game, the availability of a dispute between us and the User, conduct of financial control and accounting, etc. As for the detecting violations, be aware that we use anti-cheating tools that collect information about the processes in use while you are accessing Game.

The User can modify and/or erase the data provided to them, except for those specified in this section as unalterable. The user may edit his personal information having access to his private account. All changes are logged.

(3) For publicly available information

Our Sites may also have message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum, or chat area, please be aware that the information is being made publicly available on-line; therefore, you are doing so at your own risk. If your personal information is posted on one of our community forums and you want to remove such information, please inform us with request to its removal.

(4) With Anti-cheat and anti-fraud companies,

We share the information required for our detection, investigation, and prevention of cheating in the Game and violations of agreements related to the Game only for the purposes of detection, investigation, and prevention of cheating in the Game.

(5) When our control is changed

We may share your data as part of our company’s sale, merger or change in control, or preparation for any of these events. Any entity which buys us, or part of our business will have the right to continue using your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

6. Retaining and Deleting Personal Data

We retain your Personal Data only for the period of time as necessary to achieve the particular purpose for which the information was processed. Typically, without your request to erase Personal Data and also without legitimate reason to keep it longer, after the termination of our relationship, we retain your information for 1 month after deregistration of your Game Account or for the duration described in the table below:

For the clarity, we retain your information insofar as such information will be processed solely for archiving purpose in the compliance with our legal obligation or statistical purposes, subject to appropriate safeguards, in accordance with the data protection laws, for your rights and freedoms. The appropriate safeguards shall ensure that technical and organizational measures are in place to ensure respect for the principle of data minimization.

7. Age to use our Services

You must be at least 16 years of age to use our services and we do not knowingly collect any personal information from children under the age of 16. If we learn that we have inadvertently gathered Personal Data from those under the age of 16 we will take reasonable measures to promptly erase such information from our records.

If we also are informed that anyone under the age of 16 is using our services through a parent or other legal guardian, we will we will take reasonable measures to promptly erase such information from our records.

If someone is suspected of using our services and is under the age of 16 we may also look to ban them from using our services.

You can contact us at EURep@warpportal.com to inform us if someone under 16 years old is using our services at anytime.

8. Your Privacy Rights

(1) Right to Access

You are entitled to confirmation as to whether or not we process your Personal Data and, where we do, access to the Personal Data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Data concerned, and the recipients of the Personal Data. We will supply you a copy of your Personal Data. You can access your Personal Data by logging into your Game account or contacting us at EURep@warpportal.com.

(2) Right to Rectification

You are entitled to have any inaccurate Personal Data about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about you completed. You may change or update the profile information by logging into your Game account or by contacting us at EURep@warpportal.com.

(3) Right to Erasure

In some circumstances, you are entitled to the erasure of your Personal Data without undue delay. Those circumstances include: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing; (iii) you object to the processing; (iv) the Personal Data must be erased to comply with a legal obligation and (v) the Personal Data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: (a) for exercising the right of freedom of expression and information; (b) for compliance with a legal obligation; (c) for public interest or (d) for the establishment, exercise or defense of legal claims.

If you choose to terminate or delete your Game account, we will immediately delete your Game account information. 

If a User requests the erase of the Personal Data, while a prior request (s) from that User is still being processed, such data can be erased only when the User has recalled/canceled all previous requests.

You may request the erasure of your information by visiting the Sites or by contacting us at EURep@warpportal.com. 

(4) Right to Restrict Processing

In some circumstances, you are entitled to restrict the processing of your Personal Data. Those circumstances are: (i) you contest the accuracy of the Personal Data; (ii) processing is unlawful, but you oppose erasure; (iii) we no longer need the Personal Data for the purposes of our processing, but you require Personal Data for the establishment, exercise or defense of legal claims; and (iv)during the verification of the prevalence of the legitimate interest that we pursue regarding the Personal Data processing on yours. Where processing has been restricted on this basis, we may continue to store your Personal Data. However, we will only otherwise process it: (a) with your consent; (b) for the establishment, exercise or defense of legal claims; (c) for the protection of the rights of another natural or legal person; or (d) for reasons of important public interest.

You may request the restriction of the processing of your information by visiting the Sites or by contacting us at EURep@warpportal.com.

(5) Right to Object to Processing

You have the right to object to our processing of your Personal Data, at any time, on grounds relating to your particular situation, but only to the extent that the lawful basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You may object to the processing of your information by visiting the Sites or by contacting us at EURep@warpportal.com.

(6) Right to Object to Processing for Direct Marketing Purposes

You are entitled to object to our processing of your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your Personal Data for this purpose. 

You may object to the processing of your information for direct marketing purposes by visiting the Sites or by contacting us at EURep@warpportal.com.

(7) Right to Object to Processing for Statistical Purposes

You have the right to object to our processing of your Personal Data for statistical purposes. We do statistical processing for analyzing game data for analysis and optimization of the service and advertising campaigns which can include the users device or IP information.

You may object to the processing of your information for statistical purposes by visiting the Sites or by contacting us at EURep@warpportal.com.

(8) Right to Data Portability

To the extent that the lawful basis for our processing of your Personal Data is: 

• consent; or
• that the processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract, and such processing is carried out by automated means, and you have the right to receive your Personal Data from us in a structured, commonly used and machine-readable format and the right to have your Personal Data transmitted to another controller. 

You may request to receive your information by visiting the Sites or by contacting us at EURep@warpportal.com.

(9) Right to Complain to a Supervisory Authority

If you consider that our processing of your Personal Data infringes data protection laws, you are entitled to file a complaint with a supervisory authority responsible for data protection.

You can find more details of the supervisory authority in your country by visiting

http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

For the UK: https://ico.org.uk/make-a-complaint

(10) Right to Withdraw Consent

To the extent that the lawful basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may withdraw your consent at any time in the Game setting or contacting us at warpportalmobile@warpportal.com.

You may also exercise any of your rights concerning your personal data by written notice to us at EURep@warpportal.com. 

9. Change/Update to Privacy Policy

We may amend, at our discretion, any portion of this Privacy Policy at any time by posting or displaying the amended Privacy Policy within and/or on the Sites. We request your reading confirmation for each of these amendments. Except as otherwise stated, any such amendments will be automatically effective after they are initially posted. We will notify you about any significant changes in our Policy. This policy was last updated on January 22th, 2021.

10. Links

The Service may contain links to other websites. The fact that the Service links to a website or presents a banner ad or other type of advertisement does not mean that we endorse or authorize that third party, nor is it a representation of our affiliation with that third party. We are in no way responsible for the privacy policies of these other websites to which you choose to access from the Services. It is your responsibility to read the privacy policies of these other websites when exiting the Services.

11. Questions

If you have any questions regarding our Privacy Policy and/or practices, please email us at EURep@warortal.com or warpportalmobile@warpportal.com.

GRAVITY INTERACTIVE, INC.