(For EEA and UK Residents)
(Effective Date: January 22th 2021)
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 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.
|Gravity Co. Ltd.||R&D Tower 15F, Nuritkum Square, 396 Worldcup Buk-ro, Mapo-Gu, Seoul, Korea||IP Holder|
|Shanghai The Dream Network Technology Co., Ltd.||Room 105, Building 7, No.328, JiaJian Road, JiaDing District, Shanghai, PRC.||Co-Developer|
|X.D. Network Inc.||A2, No.700,Wanrong Rd.,Zhabei Dist. Shanghai, PRC.||Co-Developer|
|X.D. Global Limited||FALT/RM A 21/F, Nathan Tower, 518-520 Nathan Road, KL, Hong Kong||Service Performer|
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.
|Ragnarok M: Eternal Love EU||https://www.facebook.com/PlayRagnarokMEU|
|Ragnarok M: Eternal Love EU||https://romeleu.com/|
|Ragnarok M: Eternal Love EU||https://www.youtube.com/channel/UCvAZZZ57xNatmUK2oVfZdHw/featured?sub_confirmation=1|
|Ragnarok M: Eternal Love EU||https://twitter.com/PlayROMEU_EN|
The Personal Data is processed by:
Company Name: Gravity Interactive, Inc.
Official Address: 7001 Village Drive Buena Park, CA 90621, California
Contact Email: email@example.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 : firstname.lastname@example.org.
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:
For these purposes, we process the following Personal Data:
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:
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.
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:
When the User use credit cards for payment purposes, the Data required are:
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:
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:
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.
|Name||Data Storage Place||Transferred Data||Relevant Contact|
|Google Play||Dublin, Ireland||Information about in-game purchases||https://policies.google.com/privacy?hl=en|
|App Store||Aabenraa, Denmark||Information about in-game purchases||https://support.apple.com/en-ie/HT210584|
(2) With data storage partners, we share your Personal Data
|Name||Data Storage Place||Transferred Data||Relevant Contact|
|Zenlayer Inc||Frankfurt, Germany||Information about user’s game role||https://www.zenlayer.com/privacy-policy|
|ALICLOUD||Frankfurt, Germany||Information about user’s game role||https://www.alibabacloud.com/help/faq-detail/42425.html|
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
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:
|Personal Data Retained||Retention Period|
|Data necessary for performance of the agreement or cancellation of subscription|
Records of payment
Tax and accounting records
Records of electronic financial transaction
|Records of a customer complaint or dispute resolution|
Records that Game account or character was banned based on the violation.
|Records of correspondence with User for statistics purposes; to deliver, develop and improve our Service and the Game; to support Users in using the Services and the Game; to ensure security and confidentiality of the User’s account and data; to restore access to the User’s account, Services and/or to the Game; to restore lost payments made by the User.|
Record of User’s Game' preferences, progress in Game, playtime, as well as information about device settings, unique device identifiers and crash data.
|1 year unless stipulated more specifically in other agreements|
|Record of in-game character activities, logs, and data on in-game transactions, log-files and in-game chats.|
Records of misuse by users of Game or Services
|Computer communication or internet log-in records of computer communication or facts about an internet user’s utilization of telecommunication service||3 months|
|Record of IP address and other online identifiers||2 months|
|Log-files and chat in case of dispute with the User||The duration of the dispute|
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:
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
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 email@example.com.
You may also exercise any of your rights concerning your personal data by written notice to us at EURep@warpportal.com.
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.
GRAVITY INTERACTIVE, INC.