PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE
Privacy Policy
Last Updated: [13 May 2022]
Thank you for
using our products and services! We respect your concerns about privacy
and appreciate your trust and confidence in us.
Here is a summary of the information contained in this privacy policy.
This summary is to help you navigate the privacy policy and it is not a
substitute for reading everything! You can use the hyperlinks below to jump
directly to particular sections.
What information do we need to provide the
Game Services?
If you register an account to use the Game then we will need some
information from you to set this up. We will also process some information when
you use the Game (e.g., to make sure your progress is saved) and when you buy
items (e.g., to ensure you get the purchased content). If you choose to
set up your Game profile using a social media account, we also collect
information from that social media account. If you choose, you can provide
certain other information to personalise the gaming experience and enable Game
features, or participate in Game Services. If you need to get in touch
with us then we will also retain some information so that we can get back in
touch with you and address any concerns. More
Information.
How will we use your information?
We use your information to provide the many
functions and services that comprise the Game Services. We also use
your information for account verification, security purposes, to support and
improve the Game Services, to process transactions as part of the Game
Services, and to provide you with game updates. We do not share your
information with any third parties, except where
we need to in order to provide the Game Services (e.g., use local cloud
providers or to back up your data; using our affiliates around the world to
help us to deliver the Game Services) or monitor the success of our marketing
and advertising programs, or where we are instructed to by a court, authority
or compelled by law. More
Information.
Who do we share your information with?
We use some third parties to help us deliver the best possible
experience (e.g., cloud services to back up your data, support ticketing and
fraud detection). When we use a third party, we only do this to process or
store your information for the purposes described in this privacy policy. We
also have affiliates around the world who help us deliver the Game Services and
we may be required by a court or legal obligation to disclose certain information
in some circumstances. More
Information.
Where do we process your information?
Our servers are located in India (in the case of users located in
India only), Russia (in the case of users located in Russia only), Singapore
and the United States. Your information can be accessed from outside of where
you live by our support, engineering and other teams around the world,
including Singapore, the People’s Republic of China, India, Indonesia and the
United States. More Information.
How long do we keep hold of your information?
We generally retain your information for the period during which you
maintain an account for this Game after which time
your data is deleted (as further described in this privacy policy), unless
otherwise required by applicable laws. More Information.
How can I exercise my rights over my information?
Depending on where you live, you may have certain rights with respect to
your information, such as rights of access, to receive a copy of your data, or
to delete your data or restrict or object to our processing of your data. More Information.
How to get in touch with us
If you have any questions about anything in this policy, or want to
exercise any rights you may have, please contact us here.
How will we notify you of changes?
If there are any significant changes to this privacy policy, we will
update the policy here. More Information.
Contact Information
Data Controller: Proxima Beta Pte. Limited | Email: dpo@proximabeta.com
EU Representative: Proxima Beta Europe B.V. | Email: dpo@proximabeta.com
UK Representative: Image Frame
Investment (UK) Limited | Email: dpo@proximabeta.com
Serbia Representative: Karanovic
& Partners o.a.d. Beograd. | Email: local.representative@karanovicpartners.com
Turkey Data Controller Representative:
Özdağıstanli Ekici Avukatlık Ortaklığı. | Email: turkeydatarep_proximabeta@iptech-legal.com (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 authorized for any other matters
such as in-Game conduct, bans, investigations, civil or criminal complaints.)
Welcome to PLAYERUNKNOWN’S BATTLEGROUNDS
MOBILE!
This
privacy policy explains the when, how and why when
it comes to the processing of
your personal information in connection with the mobile game PLAYERUNKNOWN’S BATTLEGROUNDS
MOBILE (“Game”) and the website for the Game (“Website”) (the
Game and the Website together comprise the “Game Services”), and sets
out your choices and rights in relation to that
information. Please read it carefully – it is important for you to
understand how we collect and use your information, and how you can control it.
If you do not agree to the processing of
your personal information in the way this privacy policy describes, please do not provide your information when
requested and stop using the Game Services. By using the Game or the
Website, you are accepting our rules regarding your personal information as
described in this privacy policy.
This Game has been developed
by Proxima Beta Pte. Limited (“we”, “us”, “our”).
For the purpose of data protection
laws, the data controller of your personal information in relation to the
Game Services is Proxima Beta Pte. Limited. The registered address
of Proxima Beta Pte. Limited is 10 Anson Road #21-07
International Plaza, Singapore.
Our data protection officer can be
contacted at dpo@proximabeta.com.
Our representatives for data
protection purposes in certain jurisdictions are as follows:
|
EU |
Proxima Beta Europe B.V. |
Gustav Mahlerplein 2, 1082 MA,
Amsterdam, the Netherlands |
|
|
UK |
Image Frame Investment (UK) Limited |
Suite 1,
3rd Floor, 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB |
|
|
Serbia |
Karanovic & Partners o.a.d.
Beograd |
Resavska 23, Belgrade, 11000,
Serbia |
local.representative@karanovicpartners.com |
|
Turkey |
Özdağıstanli Ekici Avukatlık
Ortaklığı. |
Nidakule Ataşehir Kuzey Begonya Sok. No:3 Kat. 17 D: 162 34746 Ataşehir / İstanbul,
Türkiye |
turkeydatarep_proximabeta@iptech-legal.com |
Please reach out to us if you have any questions
or concerns regarding the processing of your personal information: you can
contact us anytime at dpo@proximabeta.com.
1. The Types of Personal Information We Use
This section describes the different types
of personal information we collect from you and how we collect it. If you would
like to know more about specific types of
data and how we use that data, please see the section entitled “How We
Use Your Personal Information” below.
The following is a high-level summary of
the types of personal information we use:
1. Information you provide to us (either directly or
through a third party).
You give us information about you when you
register for the Game (your nominated nickname, and information we import from
your connected social media account (WeChat, Facebook, QQ, VKontakte, Twitter,
Google Play, Game Center or LINE) in order to set up your profile, including
your name as it appears on your social media profile, your user ID and your
profile picture). For certain regions, you may also be asked to provide us with
your date of birth (stored device-side only) to verify your age and for
administration of the gameplay management system. If you are located in certain
regions, we may ask you to provide an email address for the purpose of
verifying parental or guardian consent to use the Game services if you are
under the relevant minimum age. You also provide us with information when you
set up your profile for the Game (including region location and information you
voluntarily elect to provide in order to customise gameplay, such as gender) or
your nickname when you log-in as a ‘guest’ in order to use the Game.
Once a Game account is set up, you may
also choose to provide us with your mobile phone number or email address and a
password, which you may select yourself for the purposes. These will be bound
to your account (once verified by way of a verification code we will send to you)
for the purposes of enabling login by email or mobile phone number. If you
choose to bind your phone number or email address with your account, you will
have the option to login via your mobile phone number or email address and we
will access your phone number or email address to verify you as a user without
you having to enter a validation code or password every time you login. If you
choose to bind your email address, we will send an account security alert to
your email address if we detect any suspicious activity. If you would like to
be featured on leaderboards, you will also be asked to bind your mobile phone
number. For certain regions, we will ask you to bind your telephone number with
your account when you change your location setting.
In addition, you may choose to provide
your location (province and city) to use region-specific features, for example,
our Battle Zone Leaderboard, People Nearby and Regional Chat Channel features.
You also provide us with information when you participate in a survey in the
Game (in which case we will process the information you provide to us as part
of the survey, including country, age, gender, profession and email address).
When you participate in one of our sweepstakes events, which may be conducted in-Game,
on our Website or otherwise, you provide us with information including email
address, Open ID, phone number, mailing address and country; when you register
for a tournament, we will collect your
name, email address, country/region and player UID;
and when you register for an e-sports event, we will collect your team name,
registration region, team logo, your name, nationality or residency, email
address, Discord ID (if applicable) and character ID. If you qualify to attend
in person an e-sports event, we will also ask you for your ID or passport
information, date of birth, gender, home address, phone number, photo and
social media profile. If you are banned from participating in
tournaments or e-sports events for cheating or otherwise violating tournament
or e-sports event rules, we use your name and date of birth to prevent you from
registering for tournaments and e-sports events during the duration of the ban.
If you participate in one of our game-based events,
to send you digital prize(s) if you win such prize(s), we will process your
email address and telephone number; to deliver physical prize(s) if you win
such prize(s), we will process your name (as shown on your passport), email
address, telephone number, mailing address and postal code; and if you share
the event with your friends, we will process your friends list.
You provide us with your telephone number
and/or email address if you choose to receive information on our game updates
via email and/or SMS. For data subject requests, we will collect information to
verify your identity, your rights and to process the requests, including
country/region, alias, user email address, screenshot of Game avatar, account
ID, account registration date, account UC balance, account BP balance, request
details, and if applicable, name of requestor, email address of requestor,
requestor's relationship with user, proof of requestor's identity, proof of
user's identity and requestor's authority.
2. Information about you generated as part of the Game (and its in-Game
services)
We automatically collect certain data from
you when you use the Game Services, namely your open ID, IP address, device
information (such as application version, battery level, WiFi strength,
available space, network type, OS version, platform, carrier, country code,
series ID, Android ID, IDFV, XID (if you are a
guest user, generated from your existing device information, model,
manufacturer, Android ID), WiFi SSID (stored device-side only) and time zone
settings), registration time, login time, battle
performance information, and information
regarding your use of the Game Services, such as date and time stamps of
actions. We also collect and store your data:
·
each
time you interact with us, for example, when you use in-app or in-Game support
to communicate with us;
·
if you
choose to log in using a social media service, we import the social media user
ID and name of the friends (and in the case of Facebook, their Facebook
nickname and profile picture) from your social media profile so that you can
connect with your friends, invite them to team
up and share game activities with your friends;
·
if you
click on a link that advertises the Game, we store the Advertising ID for that
advertisement and select device information with your profile;
·
if you
enable chat services (audio and/or text and use them whether inside or outside
a battle) then we will process such data in order to deliver your messages to
other users;
·
if you
conduct any transactions within the Game or via a third party other than Google
Play or iOS App Store, we collect information to facilitate your transaction
and to maintain transaction records (including Open ID, Role ID, country and user information, cost,
currency, product purchased, purchase history, IP address, details of transactions
linked to player ID, and device details such as IDFV, network type,
network monitoring data, client exports IP, SDK version, application version, OS version, phone model or type of device, internet
connection);
·
if you
request for a refund, we use your transaction ID, delivery status, consumption status, refund recommendation and user
account flag to help inform and improve the refund process;
·
if you
change your location setting, we use your IP address to suggest your current
location;
·
if you
have poor network connection, we collect your routing information to analyse
the cause to allow you to play the game;
·
if you
qualify for a tournament, we use your UID to invite you to participate;
·
if you
take an in-Game screenshot, we will process such data (device-side only) to
facilitate your sharing of the screenshot on social network;
·
if you
enable our highlights replay function, we use your Game operation records,
nickname, profile picture and ranking information to provide highlights replay
videos that you can share;
·
if you
are a highly-ranked player, your battle replay video may be featured as part of
the highlights showcased from time to time in-Game;
·
if you
choose to participate in our Beta test, the following information will be used
to verify your eligibility: your login credentials, Open ID, account type, Game
level, frequency of use of Game, whether your Game account is bound to a Beta
test account, and whether you have cheated in the Game;
·
for users
in certain regions, if you participate in a group photo event, we process the
photo you upload (processed device-side only), the photo generated (processed
device-side only), your UID, Open ID and your election to share the photo
generated;
·
for users
in certain regions, if you create or join clans,
share picture, text or video content, create or join custom matches or
otherwise use the Club feature: (i) we process your UID, Open ID, avatar, rank,
country and region, province, city, language, nickname, friends list, joined
clans, custom room game data, eligibility tag and picture, text and video
content you share publicly in the Club or with other clan members; (ii), we will
process your Open ID, social media account nickname and content if you choose to showcase content posted on your social
media account in-Game; (iii) our content audit feature will detect if any picture, text and video
content you share in the Club or with other clan members contains pornography
or other content that violates the Community Guidelines or the End-user License Agreement and remove content in such cases; (iv) we will process your Open ID, carrier, WiFi status, device model,
operating system, frame rate, page load time, memory, exception error and stack
to optimize the performance of the Club functions and provide a better
user experience;
·
if you apply to be
reviewers of user-generated content, we process your nickname, user profile,
UID, Open ID and Facebook ID;
·
if you share replay
videos with your friends on your Moments page, we process your nickname, avatar
and any replay videos generated
with game operation records that you share;
·
if you add event
schedule information to your system calendar, this will be provided device-side
only;
·
for users
in certain regions, when you are using the Game Services, we collect your daily
cumulative gameplay time and your daily rest time to prevent gaming addiction;
·
if you
contact our support team, we collect information including name (optional),
Open ID, device ID, application version, battery level, WiFi strength, free
space on device, network type, OS version, browser type, platform, carrier,
country code, details of ticket, email address (optional if in-app/in-Game
support) and any information that you provide in your communications. You also
have the option of providing a photo to illustrate any errors;
·
when you
are using the Game Services our security feature collects (in addition to the
categories of data listed above) device information including IDFV, Android ID
and available memory; and a list of installed APK and running apps; and
·
when you
are using the Game Services, our security and anti-cheating security features
will (i) monitor users to identify and observe cheating behaviour; (ii) collect
(in addition to the categories of data listed above) user’s in-Game
instructions to generate an in-Game behavior video clip of suspected cheating
behaviour for our review; (iii) detect if your profile picture is related to
the sale of plug-ins or pornographic content and change it to a default profile
picture if this is the case; (iv) identify abuse, harassment, the sale of
plug-ins or other conduct in violation of our End-user
License Agreement and
restrict your use of the chat functions where you have engaged in any of the
foregoing if this is the case; (v) detect if your signature, nickname, profile
photo or chat history contains malicious information and changing it to its
default setting and prompting you to change it subsequently if this is the
case;
(vi) detect if you are using tools to
cheat, take screenshots where there is suspected cheating behaviour for our
review and restrict your use of the Game if this is the case and (vii) review
in real-time games of users suspected of cheating.
3. Information you generate and display in the course
of using the Game Services.
You may provide additional information as
part of your profile (such as gender). You may also provide or generate
information when you communicate with other users in the Game (chat log data
and chat content, both audio and text). We generate an Open ID and use this to
store your Game data, and we collect and store your Game play statistics (e.g.
level, scores) in order to provide you with feedback, information about your
Game play and progress. If you participate in a sharing event, we will process
your Game data (prop types, wins, ranking and Game play statistics) to prepare
a report for you and process your friends list so you can share game activities
with your friends. Your Game data and country/region are also used to determine
if you qualify for, and to invite you to participate in, a tournament.
4. Beta features.
You may have the opportunity to use “beta”
features for a limited period of time. These may be accompanied by a notice or
flag indicating that they are in “alpha”, “beta”, “test” mode, or similar.
These features are made available to help us test new ideas and improvements
for the Game. By agreeing to participate in a beta, you understand that we may
process data as part of these features in order to ensure the features can
function properly and (once the beta period has concluded) to understand
whether it makes sense to modify or rollout those features to the broader
community. We may also seek your feedback so that we can understand your
experience of the features. We will only process personal data for so long as is
necessary for us to fulfil these purposes, and thereafter will take steps to
delete or de-identify your personal information (including any feedback you
provide).
Cookies
We use cookies and other similar
technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”)
to enhance your experience using the Game Services. Cookies are small files
which, when placed on your device, enable us to provide certain features and
functionalities.
You have the option
to permit installation of such Cookies or subsequently disable
them. You may accept all cookies, or instruct the device (in the case of the
Game) or web browser (in the case of the Website) to provide notice at the time
of installation of cookies, or refuse to accept all cookies by adjusting the
relevant cookie retention function in your device. However, in the event of
your refusal to install cookies, the Game Services may be unable to
operate as designed.
For more information about our Cookies
policy, click here.
Children
Our Game Services are not intended for
children. Children must not use the Game Services for any purpose, except where
their parent or guardian has provided 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 minimum
relevant age in the table below.
|
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/Switzerland |
16 |
|
Hong Kong |
18 |
|
India |
18 |
|
Indonesia |
21 |
|
Kingdom of Saudi Arabia |
18 |
|
Kuwait |
21 |
|
Macau |
18 |
|
Malaysia |
18 |
|
Mexico |
18 |
|
Morocco |
18 |
|
Myanmar |
18 |
|
New Zealand |
16 |
|
Nigeria |
13 |
|
Philippines |
18 |
|
Qatar |
18 |
|
Russia |
14 |
|
Serbia |
15 |
|
Singapore |
13 |
|
South
Africa |
18 |
|
Sri
Lanka |
18 |
|
Thailand |
20 |
|
Tunisia |
18 |
|
Turkey |
18 |
|
United Arab Emirates |
21 |
|
United Kingdom |
13 |
|
United States |
13 |
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
parental or guardian consent, or
if you are the parent or guardian of the user and wish to withdraw the consent,
please submit your request at https://www.pubgmobile.com/datasubject
or contact us at dpo@proximabeta.com and
we will delete such information.
2. How We Use Your Personal
Information
This section provides more detail on the
types of personal information we collect from you, and why. For users who live
in the United Kingdom, the European Economic Area, Switzerland, Thailand,
Brazil or Turkey (“Relevant Jurisdiction”), it also identifies the legal
basis under which we process your data.
|
Personal Information |
Use |
Legal Basis (only relevant if you are located in a
Relevant Jurisdiction) |
|
Game |
||
|
Information you provide to
us (either directly or through a third party). |
||
|
Nickname |
We use this information to create your account for the Game in
accordance with your request. |
Necessary to perform our contract with you to provide the Game. |
|
Hashed Nickname / Gamer Tags |
If your account is determined to breach our Terms of Service or
otherwise is found to be undertaking activity which is illegal, defamatory,
damaging to the platform or similar, and your account is consequently banned,
we may publish a hashed version of your nickname on our Website and in the
Game (including via in-Game pop-up). |
It is in our
legitimate interest to ensure the security of our services and to maintain a
fair gaming environment within the Game, including notifying other players if
a participant has been removed for behavior that violates the Terms of
Service. |
|
Social Connect Information (if you choose to log in via your social media
account with these networks):
|
We use this information to: · create
your account for the Game in accordance with your request; and · share
in-game photos on WeChat, Facebook, VKontakte, QQ, Twitter, Google Play, Game
Center or LINE (as applicable) at your request. |
Necessary to perform our contract with you to provide the Game. |
|
Gender (if you
elect to provide this information) |
We only receive this information if you voluntarily provide it (other
than users who log in via their QQ or WeChat social media account, when
gender is also collected – please see above). It is used in order to customise
gameplay. |
Necessary to perform our contract with you to provide the Game with
gender-specific content in accordance with your request. |
|
Date of Birth (not stored) |
We use your date of birth to verify your age if you are a user in
certain regions. This is processed device-side only and is not transferred to
us. |
N/A. |
|
Email address (for verification of parental or guardian consent) |
If you are located in certain regions,
we may ask you to provide an email address for the purpose of verifying parental
or guardian consent to use the Game services if you are under the relevant
minimum age. |
Necessary to perform our contract with you to
provide the Game. |
|
Region Location (manually selected by you) |
We use this information to: ·
verify your region
location; ·
set up your
gameplay on a regional server; ·
provide you with
your geographic ranking; and ·
improve gameplay. |
Necessary to perform our contract with you to provide the Game. |
|
Friends List (WeChat, Facebook, QQ, VKontakte, Twitter) |
If you choose to log-in using a social media service, we import the
social media user ID and name of the friends from your social media profile
so that you can connect with your friends and share game activities with your
friends. If you choose to log-in through Facebook, and connect with your
friends that also have the Game, we will import the Facebook nickname and
profile picture of those friends. |
Necessary to perform our contract with you to provide the Game and
connect you with your friends. |
|
Friends List (manually added by you) |
We use this information so that you can connect with your friends and
share game activities with your friends. |
Necessary to perform our contract with you to provide the Game and
connect you with your friends. |
|
Telephone number and/or email address (if you elect to provide this information to receive game updates). In
relation to your telephone number, this includes
your telephone number, country code and SMS content (“SMS Sending Records”) |
We use this information to send you verification codes or information
on our game updates via SMS or email. |
We collect this information with your consent. |
|
Email address (if you elect to
provide this information to bind your account with your email address) |
We only receive this information if you choose to
enable login by email address (once verified by way of a verification code we
will send to you). |
Necessary to perform our contract with you to provide the Game using
your email address. |
|
Telephone number (if you elect to provide this information to bind your account with
your telephone number). This includes SMS Sending Records |
We only receive this information if you choose to
enable login by mobile phone number (once verified by way of a verification code we will
send to you). |
Necessary to perform our contract with you to provide the Game using
your phone number. |
|
Telephone number and User ID (if you elect to be featured on leaderboards). In relation to your
telephone number, this includes SMS Sending Records |
We use this information to bind your account with
your telephone number and send you SMS verification codes if you would like
to be featured on leaderboards. |
It is in our legitimate interest to ensure the security of our
services and to maintain a fair gaming environment within the Game. |
|
Telephone number (when you provide
this information to bind your account with your telephone number to change
your location setting in certain regions). In relation to your telephone
number, this includes your telephone number and country code |
We use this information for the purposes of enabling
login by mobile phone number if you choose to change your location setting in
certain regions. |
We collect this information with your consent. |
|
Location information (province and city manually selected by you) and
nickname |
We use this information if you voluntarily provide
this to enable your use of region-specific features, for example our Battle Zone
Leaderboard, People Nearby and Regional Chat Channel features. |
Necessary to perform our contract with you to provide region-specific
features. |
|
Game-based Event Information (digital prizes): email address and telephone number |
If you participate in a game-based event, we use your contact
information to send you your prize if you win. |
N/A. |
|
Game-based Event Information (physical prizes): name (as shown on passport),
email address, telephone number, mailing address and postal code |
If you participate in a game-based event, we use your contact
information to send you your prize if you win. |
Necessary to perform our contract with you to deliver your prize. |
|
Data Subject Request Information: country/region, alias, user email address,
screenshot of Game avatar, account ID, account registration date, account UC
balance, account BP balance, request details, and if applicable, name of
requestor, email address of requestor, requestor's relationship with user,
proof of requestor's identity, proof of user's identity and requestor's
authority |
If a data subject request is submitted, we use this
information to confirm the requestor’s identity, your rights and to process
the request. |
Necessary to comply with a legal obligation. |
|
Information generated
as part of the Game (and its in-Game services) |
||
|
Generated Open ID |
We generate this and use this to store your Game data (including level
and progress) with your profile, and to support your use of the Game and Game
activities. |
Necessary to perform our contract with you to provide the Game. |
|
Game Play Statistics (Level, Score/s), date and time stamps of actions |
We use this information to provide you with feedback and information about
your gameplay and progress. |
Necessary to perform our contract with you to provide the Game. |
|
IP Address |
We use this information to:
|
Necessary to perform our contract with you to provide the Game. |
|
Device ID, Device Information (application version, battery level, WiFi strength,
available space, network type, OS version, platform, carrier, country code,
series ID, Android ID, IDFV, device language, screen DPI, device resolution,
screen direction, brand, manufacturer, device model, XID (if you are a guest
user, generated from your existing device information, model, manufacturer,
Android ID), time zone settings, RAM, ROM and CPU information), registration
time and login time |
We use this information:
·
to combat users
registering for multiple accounts. |
It is in our legitimate interest to ensure the security of our
services, manage registrations and improve our services. |
|
Routing Information (if you have poor network connection): IP address, network speed |
We use this information to analyse the cause of poor network
connection. |
Necessary to perform our contract with you to allow you to play the
Game. |
|
WiFi SSID (not stored) |
We use this information to download the Game in the background. This
is processed device-side only and is not transferred to us. |
N/A. |
|
Advertising ID and select device information (Open ID, Device ID, IP address and engagement data
and search terms) |
If you click on a link that advertises the Game, we store the
Advertising ID for that advertisement and select device information with your
profile. |
It is in our legitimate interests to use this information to monitor
the success of our advertising and marketing programs. |
|
Chat Data (audio and text, whether inside a battle (e.g. during actual
gameplay) or outside a battle (e.g. in the game lobby)) and chat log data |
If you enable chat services (audio and/or text) then we will process
such data in order to deliver your messages to other users. |
Necessary to perform our contract with you to provide the chat
services in-Game. |
|
Transaction Records (in-app): payments on Google Play or iOS App Store (Open ID,
Role ID, country, currency, cost, product purchased, IP address, details of
transactions linked to player ID, and device details including IDFV, network
type, network monitoring data, client exports IP, OS version, phone model,
device root status, SDK version, application version). |
We use this information to facilitate your payment and maintain a
record of your transaction history. |
Necessary to perform our contract with you to facilitate your payment
and provide you with details of your transactions. |
|
Transaction Records (third party other than Google
Play or iOS App Store): user information
(name, username, email address, Facebook nickname), device information
(including Open ID, Role ID, App ID, package name, API call status, WiFi,
storage and network access permissions, IP address, OS version, type of
device, internet connection), transaction details (time and date, cost,
product purchased, currency, order ID, subscription information (including
subscription ID)) and transaction records (including player ID, time of
transaction, country, email, phone number, purchase history and payment card
details). |
We use this information to facilitate your payment and maintain a
record of your transaction history. |
Necessary to perform our contract with you to facilitate your payment
and provide you with details of your transactions. |
|
Transaction Identifiers: unique identifier, name, email address, phone number, country code,
date of creation of account, number of transactions during different periods,
number of top-ups during different periods, number of top-up receivers, number
of chargebacks. |
We use this information in order to detect fraud on the Game Services. |
It is in our legitimate interest to ensure the security of
transactions within our services. |
|
Refund information: transaction ID, delivery status, consumption status, refund
recommendation and user account flag. |
We use this information to help inform and improve the refund process
if you request a refund. |
Necessary to perform our contract with you to facilitate your refund
process. |
|
Customer Support Ticket ID & User Communications
with Support: Name (optional), Open ID,
device ID, application version, battery level, WiFi strength, free space on
device, network type, OS version, browser type, platform, carrier, country
code, details of ticket, email address (optional if in-app/in-Game support)
and any information that you provide in communications with our support team.
You also have the option of providing a photo to illustrate any errors. |
We use this information to: ·
improve our
services;
|
Necessary to perform our contract with you to provide and support the
Game. |
|
Safety Observation:
|
We use this information:
If your account is determined to breach our Terms of Service, we may
consider restricting or banning your access to the Game. |
It is in our legitimate interest to ensure the security of our
services, to maintain a fair gaming environment in the Game and to manage
registrations and improve our services. |
|
Illegal Profile Photos: profile pictures from logged in accounts (existing and new users) |
We use this information to detect if your profile picture is related
to the sale of plug-ins or contains pornographic content (e.g. erotic photos)
and change it to a default profile picture if this is the case. |
It is in our legitimate interest to ensure the security of our
services, to maintain a fair gaming environment in the Game and to prevent
the sale of plug-ins or the availability of pornographic content on the
services. |
|
Reported Chat Data: UID and chat data |
We use this information to identify abuse, harassment, plug-in sales
or other uses of chat in violation of our End-user License Agreement and to
consider restricting use of chat function in those cases. For more information, please refer to the Privacy FAQ for this function. |
It is in our legitimate interest to ensure the integrity of the Game
and protect users from prohibited conduct. |
|
Video Clips of Suspected Cheating Behaviour:
|
We use this information to review and determine whether users
suspected of cheating have cheated in the Game. |
It is in our legitimate interest to ensure the security of our
services and to maintain a fair gaming environment within the Game. |
|
Malicious Content Information: signatures, nicknames, profile photos
and chat histories, and email address. |
We use this information to detect if you are making available
malicious information (i.e. information relating to sale of plug-ins, UC
tokens, game accounts, information about game power levelling, or
pornographic images) via your signature, nickname, profile photo or chat
history) within the Game. We may contact you via email if we have detected
malicious activity involving your account. |
It is in our legitimate interest to ensure the security of our
services and to ensure all information made available within the Game is
legal. |
|
Cheat Tool Detection Information: resource files and parameter data,
cheating reports, screenshots of the game from your perspective (which will
contain nicknames and chats of you and your teammates (this information will
be obfuscated), number of kills and game scenes from your perspective),
number of kills, UID and nickname |
We use this information to review and determine
whether users have cheated in the Game, for example, if it is apparent you
are using a tool to remove grass in violation of the End-user License
Agreement. If your account is determined to breach our Terms of Service, we
may consider restricting or banning your access to the Game. |
It is in our legitimate interest to ensure the
security of our services and to maintain a fair gaming environment within the
Game. |
|
Real-Time Game Review Information: Open ID of players suspected of
cheating, Open ID and player level of reviewer of suspected
cheating behaviour, review results |
We use this information to review and determine whether users
suspected of cheating have cheated in the Game. |
It is in our legitimate interest to ensure the security of our
services and to maintain a fair gaming environment within the Game. |
|
Gameplay Management System Information (if you are in certain regions): daily cumulative
gameplay time and daily rest time |
We use this
information to prevent gaming addiction. |
N/A. |
|
Security-Related Information when
transactions are conducted: whether certain billing security features of
the Android SDK (security development kit) are installed on the device, and
if so the version information. |
We use this information when transactions are conducted on your
account in order to detect fraudulent payment activity. |
It is in our legitimate interest to ensure the security of
transactions within our services. |
|
Survey Information: Country, Age, Gender, Profession, Email, and content of survey
responses. |
If you agree to participate in a survey conducted by us, we use this
information to improve our services. |
We collect this information with your consent. |
|
In-Game screenshot information: whether you have taken an in-game screenshot, and
if so the in-game screenshot (which will contain
any content displayed at the time) |
We use this information to facilitate your sharing of any in-game
screenshot on social network. The screenshot is processed device-side only
and is not transferred to us. |
Necessary to perform our contract with you to facilitate sharing of
screenshots. |
|
Highlights Replay Information: Game operation records used to
generate replay videos, nickname, UID, Open ID and profile picture, linked
social media service |
We use this
information to provide highlights replay videos
that you can share within the game or on social media if you enable this
function. |
Necessary to perform our contract with you to provide highlights
replay videos that you can share. |
|
Leaderboard Highlights Information: battle replay, player nickname, game server used
by player and ranking. |
We use this information to showcase highlights of top players
in-Game. |
It is in our legitimate interest to ensure the integrity of
high-scoring players is supported by appropriate evidence in-Game. |
|
Beta Test Account Authentication Information: login credentials, Open ID, account type, Game
level, frequency of use of Game, whether your Game account is bound to a Beta
test account and whether you have cheated in the Game. |
If you seek to participate in our Beta test, we use this information
to verify your eligibility. |
Necessary to perform our contract with you to provide the Beta
version. |
|
Group Photo Event Information (if you are in certain regions): the photo you upload, the photo generated, your UID,
Open ID and election to share the photo generated |
If you participate in a group photo event, we use this information to
generate a group photo for you, to enable you to save or share the photo on
social network and, if you are eligible, to provide you with rewards. |
Necessary to perform our contract with you to support your
participation in a group photo event. |
|
Sweepstakes Participation Information: name (as shown on passport), email address, Open
ID, phone number, mailing address, postal code and country. |
If you participate in a sweepstakes event, which may be conducted in-Game, on our Website or
otherwise, we use this information to send you your prize if you win. |
We collect this information with your consent. |
|
Club Information (general): User data (UID, Open ID, avatar, rank, country and region,
language, nickname, clan information (including clan ID, name and role),
custom room game data, eligibility tag) and user-generated content (“UGC”)
(picture, text, audio and video content you share publicly in the Club or
with other clan members (including custom competition information and clan
announcements) or mirrored to a clan page from your Moments page) |
We use this information to enable you to create or join clans
(including operating and participating in custom competitions and posting
clan announcements), share picture, text or video content and create or join
custom matches. |
Necessary to perform our contract with you to provide Club services. |
|
Club Information (country and region, province, city, language, friends list) |
We use this information to recommend and display content and clans
that may be of interest to you. |
It is in our legitimate interest to show you content that may be more
relevant to you and your interests. |
|
Social Media Account Content: Content posted on your social media account, your
social media account nickname and Open ID |
We use this information to enable you to showcase content posted on
your social media account in-Game if you choose to bind your social media
account for this purpose. |
Necessary to perform our contract with you to facilitate your display
of your social media account content
in-Game. |
|
UGC Information:
|
We use this information to detect whether content shared contains
pornography or other content that violates local laws, community rules or the
End-user License Agreement and remove or block
content in such cases. |
It is in our legitimate interest to ensure the integrity of the Game
and protect users from prohibited conduct. |
|
Moments Information: nickname, avatar, replay videos generated with game operation records |
We use this information to enable you to share content with your friends
on your Moments page. You can also share such content on a clan
page. |
Necessary to perform our contract with you to facilitate your sharing
of content in-Game. |
|
Clan Announcement Information: clan announcement content |
We use this information to detect whether clan announcements contains pornography or other content that violates
local laws, community rules or the End-user License Agreement and remove or
block content in such cases. |
It is in our legitimate interest to ensure the integrity of the Game
and protect users from prohibited conduct. |
|
Schedule Subscription Information: schedule information |
We use this information to enable you to add event schedule
information to your system calendar and provide calendar reminders. This is
processed device-side only and is not transferred to us. |
N/A. |
|
Club Feature Performance Information: Open ID, carrier, WiFi
status, device model, operating system, frame rate, page load time, memory,
exception error and stack |
We use this information to optimize the performance of the Club
functions and provide a better user experience. |
It is in our legitimate interest to improve our Club services. |
|
Tournament Qualification Information: country/region and Game data (prop types, wins,
ranking and Game play statistics) |
We use this information to determine if you qualify for a tournament. |
Necessary to perform our contract with you to provide Game
tournaments. |
|
Tournament Invitation Information (free entry): player UID |
We use this information to send you in-Game invitations to free-entry
tournaments, if you qualify for such tournaments. |
Necessary to perform our contract with you to provide Game
tournaments. |
|
Tournament Registration Information (if you register for a tournament): name, email
address, country/region and player UID |
If you elect to participate in a tournament, we use this information
for registration and verification. |
Necessary to perform our contract with you to support tournament
participation. |
|
E-sports Event Registration Information:
|
If you register for an e-sports event, we use this information to
create a team for you in the tournament, to organise the tournament and to
communicate with the team. We use the ID/passport information of players who qualify to attend in
person an e-sports event to verify that you are located within a country in
your nominated Game region and to assist with travel arrangements. |
We collect this information with your consent. |
|
Player Ban Information (if applicable): name and date of birth |
If you are banned from participating in tournaments or e-sports events
for cheating or otherwise violating tournament or e-sports event rules, we
use your name and date of birth to prevent you from registering for
tournaments and e-sports events during the duration of the ban. |
It is in our legitimate interest to protect the integrity of the Game
and ensure fair play at tournaments and e-sports events. |
|
Sharing Event Report Information: Game data (prop types, wins, ranking and Game play
statistics). |
If you participate in a sharing event, we use this information to
prepare a report for you. |
We collect this information with your consent. |
|
Battle Performance Information: Battle ID, map ID, opening time, player/team UID,
number of kills by player/team, killing flow, killing count, survival time,
damage amount, heal amount, current round rank, assist count, old segment
level |
For the classic game mode, we use this information to improve resource
distribution in the battlefield. |
It is in our legitimate interest to improve our services. |
|
Offline Team
Invitation Information: Your player ID, Open ID, in-Game
friends list, Facebook name, Facebook ID, Facebook profile picture, whether
you log in via Facebook, your Facebook friends list, whether a Messenger
friend is also a player of the Game who logs in via Facebook, and if so, such
friend’s Player ID, Open ID, Facebook name, Facebook ID and Facebook profile
picture |
We use this information so that you can invite
friends to team up even when they are offline. |
Necessary to perform our contract with you to
connect you with your friends. |
|
Account Security Alert Information: Email, player ID, Open
ID, suspicious account activity, player confirmation of account security |
If you choose to bind your account with your email address, we
will send an account security alert to your email address if we detect any
suspicious activity. |
It is in our legitimate interest to ensure the security of our
services and your account. |
We may collect other personal information from you from time to time for specific reasons
(such as a promotion in your country). When this happens, we will provide
more information on any specific changes to the way we process that personal
information that might differ to this privacy policy prior to collecting or
processing any additional information. In some cases, that information may be
shared with us with your consent – and if that is the case, we will provide you
with further information on how we process that information and your rights.
3. How We Store and Share Your Personal Information
Our corporate group operates around the
world. Pursuant to our contract with you to
provide you with the Game Services, your personal information will be processed
on servers that may not be located where you live. Your information can
be accessed from outside of where you live by our support, engineering and
other teams around the world, including Singapore, the People’s Republic of China,
India, Indonesia and the United States. No matter where our servers are located, we take
appropriate measures to safeguard your rights in accordance with this privacy
policy. Our servers for the Game Services are located in:
·
India (in the case of users located in India only);
·
Russia
(in the case of users located in Russia only);
·
Singapore;
and
·
the
United States.
If you choose to provide us with your telephone number
and/or email to receive information on game updates via SMS and/or email and in
order for us to send you SMS verification codes, your information will be
stored in the United States and Singapore. Additionally, the SMS service
providers located in Hong Kong SAR, Singapore as well as your local carrier
will have access to the data, including to the SMS Sending Records.
Only where necessary will we share your personal information
with third parties. Situations where this occur are:
·
Third
parties that provide services in support
of the Game Services, including providers of cloud and network
services that process or back up information identified in this privacy policy
on their servers for the purpose of providing the Game Services
(including the sharing of in-game photos on WeChat, Facebook, VKontakte, QQ, Twitter, Google Play, Game Center or
LINE (as applicable)), for the purpose of processing
customer support ticket IDs and support communication, for the purpose of providing marketing and
advertisements and monitoring the success of our marketing and advertising programs,
for the purpose of providing you with updates and information regarding the
Game Services, for the purpose of providing translations, for the purpose of
detecting whether user-generated content violates applicable laws, our terms or
community rules, for the purpose of arranging tournaments and e-sports events,
for the purpose of distributing digital prizes, for the purpose of delivering
physical prizes, for the purpose of payment processing services (including
security and fraud detection) and for the purpose of informing and improving the refund process if you request a refund. All companies providing services for us are prohibited
from retaining, using, or disclosing your personal information for any purpose
other than providing us with their services in support of the Game Services.
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 (exchanging
information with other companies and organisations for the purposes of fraud
protection and credit risk reduction).
4. The Security of Your Personal Information
We are committed to maintaining the
privacy and integrity of your personal information no matter where it is
stored. 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 Game Services or
otherwise via the Internet; any transmission is at your own risk.
|
Personal Information |
Retention Policy |
|
Nickname, Hashed Nickname / Gamer Tags |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. |
|
Social Connect Information:
·
QQ |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days or
as otherwise required by law. |
|
Social Connect Information: ·
VKontakte ·
Twitter ·
Facebook ·
Google Play ·
Game Center ·
Line |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Gender |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Date of Birth |
Not stored. This is processed device-side only and is not transferred
to us. |
|
Email address (for verification of parental or guardian consent) Region Location (manually selected by you) Game Play Statistics (Level, Heroes, Score/s), date and time stamps of
actions |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Location
information (province and city manually selected by you) and nickname |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 90 days after the Game is shut down, before it is deleted. |
|
Game-based Event Information (digital prizes) |
Stored for 1 year after the conclusion of the event. |
|
Game-based Event Information (physical prizes) |
Stored for 1 year after the conclusion of the event. |
|
Data Subject Request Information |
Stored for 3 years. |
|
Gameplay Management System Information |
Cached for the day and deleted every 24 hours |
|
Chat Communications (Audio message) – outside a battle (e.g. in game
lobby) |
Stored for 7 days on our servers and deleted automatically upon expiry
of such period. |
|
Chat Communications (Audio message) – inside a battle (e.g. during
actual gameplay) |
We do not store this information. Your data is not transferred through
our game servers, but it is transferred directly from client to client
through a voice-enabled service node. |
|
Chat Communications (Text) – outside and inside a battle |
Stored for 7 days on our servers and deleted automatically upon expiry
of such period. |
|
Open ID |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
IP Address |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Device ID, Device Information, registration time and login time |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days (or
within 7 days of user request for account or data deletion in respect of
XID). Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Routing Information |
Stored for 1 year. |
|
WiFi SSID |
Not stored. This is processed device-side only and is not transferred
to us. |
|
Friends List (WeChat, Facebook, QQ, VKontakte, Twitter) |
Stored for the duration of each session on the Game and deleted within
1 hour after you log out. |
|
Friends List (manually added by you) |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Advertising ID and select device information (Open ID, Device ID, IP
address and engagement data and search terms) |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Transaction Records (in-app) Transaction Records (third party other than Google Play or iOS App
Store) |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then for the duration of any
retention periods for which such data must be retained in order to comply
with our legal obligations. |
|
Refund Information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Customer Support Ticket ID & User Communications with Support |
Support data is deleted within 30 days of a lawful request from you
for the erasure of such data (see the Erasure section of this privacy
policy). |
|
Security-Related Information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. |
|
Security-Related Information (if you are using the game on a PC) |
We generally retain this data for no longer than 90 days with the
exceptions listed below. · File
sample collection and memory sample collection related to confirmed malicious
activities: up to 10 years; · In-game
process information and system information: up to 10 years; · Security
authentication: up to 5 years. Upon a deletion request, we will delete the data within 30 days except
where they relate to confirmed malicious activities. |
|
Illegal profile photos |
If no violation is found, stored for 1 day. If any violation is found, stored for the shorter of 3 years or until
account deletion in accordance with your request and then deleted within 30
days. |
|
Reported chat data |
UID and documented chat are stored for 180 days if any violation is
found. Reported chat clips are stored for 30 days. |
|
Video clips of suspected cheating
behaviour |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. |
|
Malicious Content Information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. |
|
Cheat tool detection information |
If no violation is found, stored for 1 day. If any violation is found, stored for the shorter of 3 years or until
account deletion in accordance with your request and then deleted within 30
days. |
|
Real-Time Game Review Information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Survey Information |
Stored for: (a) if you provide your email as part of the survey, up to
6 months (in order for us to follow up with you) and then the data is
anonymised; or (b) if you do not provide your email as part of the survey, up
to 1 month and then the data is anonymised. |
|
In-Game screenshot information |
Not stored. This is processed device-side only and is not transferred
to us. |
|
Highlights Replay Information |
For any highlights replay video you share: Highlights Replay Information is stored for the lifetime of your use
of the Game (i.e. until account deletion in accordance with your request) and
then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 90 days after the Game is shut down, before it is deleted. For videos not shared: Not stored. Please note that any highlights published outside of the Game (for
example, to social media), may remain available via such services even if
deleted from the Game. |
|
Leaderboard Highlights Information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30
days. |
|
Beta Test Account Authentication Information |
Stored for the lifetime of your use of the Beta test (i.e. until
account deletion in accordance with your request) and then deleted within 30
days. Where you do not request for account deletion, such data will be
retained for 2 months, before it is deleted. |
|
Group Photo Event Information |
For any photo you share: The photo you upload and the photo generated are
processed device-side only and are not transferred to us. Your UID, Open ID and election to share the photo
generated are stored for the lifetime of your use of the Game
(i.e. until account deletion in accordance with your request) and then
deleted within 30 days. For photos not shared: No information is stored. This is processed device-side only and is
not transferred to us. |
|
Sweepstakes Participation Information |
Stored for 1 year after the conclusion of the sweepstakes event. |
|
Club Information (general) |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any picture, text, audio and video content you
share any time. |
|
Club Information (country and region, province, city, language,
friends list) |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Social Media Account Content |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any picture, text and video content you share any
time. |
|
UGC Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any picture, text, audio and video content you
share any time. |
|
Moments Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any video content you share any time. |
|
Clan Announcement Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any announcement you post any time. |
|
Schedule Subscription Information |
Not stored. This is processed device-side only and is not transferred
to us. |
|
Club Feature Performance Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Tournament Qualification Information |
Stored for up to 6 months from the time of collection. |
|
Tournament Invitation Information (free entry) |
Stored for up to 6 months from the time of collection. |
|
Tournament Registration Information |
Stored for 3 months from the time of collection. |
|
E-sports Event Registration Information |
Stored for up to 3 months from the conclusion of the
tournament. |
|
Player Ban Information |
Stored for the duration of the ban. |
|
Sharing Event Report Information |
Stored for 1 year after the conclusion of the event. |
|
Battle Performance Information (other than number of kills) |
Deleted when the battle is over. |
|
Battle Performance Information (number of kills) |
Stored for 21 days. |
|
Telephone number or email for the purposes of binding your account
with your telephone number and/or email address and for providing game
updates SMS Sending Records |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 1 year after the Game is shut down, before it is deleted. SMS Sending Records will be stored by the SMS service provider for
three months after which they will be deleted automatically. |
|
Telephone number and User ID (if you elect to be featured on
leaderboards) SMS Sending Records |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 1 year after the Game is shut down, before it is deleted. SMS Sending Records will be stored by the SMS service provider for
three months after which they will be deleted automatically. |
|
Offline Team Invitation Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Account Security
Alert Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
If we are required to retain your
information beyond the retention periods set out above, for example to comply
with applicable laws, we will store it separately from other types of personal
information.
Some jurisdictions’ laws grant specific rights to
users of the Game Services, which are set out in this section.
This section entitled “Your Rights”
applies to users that are located in the Relevant Jurisdictions. If you are
located in a territory outside a Relevant Jurisdiction, please refer to the
Supplemental Jurisdiction-Specific Terms for an overview of your rights and how
these can be exercised.
The sub-sections entitled “Access”,
“Correction”, and “Erasure” also apply to users that are located in Canada, India,
Russia
and the Kingdom of Saudi Arabia.
The sub-sections entitled “Email Opt-Out”
and “SMS Opt-Out” also apply to users that are located in Canada, Egypt, India,
Indonesia, Malaysia, Mexico, Russia, Singapore, the United Arab Emirates and
the United States.
You have certain rights in relation to the
personal information we hold about you, depending on where you are located.
Some of these only apply in certain circumstances (as set out in more detail
below). We must respond to a request by you to exercise those rights without
undue delay and at least within one month (though this may be extended by a
further two months in certain circumstances). To exercise any of your rights,
please submit your request at https://www.pubgmobile.com/datasubject.
Access
You have the right to access personal
information we hold about you, how we use it, and who we share it with. You can
access the personal information you have made available as part of your account
by logging into your Game account. If you believe we hold any other personal
information about you, please contact us at
https://www.pubgmobile.com/datasubject.
Portability
You have the right to receive a copy of
certain personal information we process about you. This comprises any personal
information we process on the basis of your consent or pursuant to our contract
with you, as described above in the section “How We Use
Your Personal Information”.
You have the right to receive this personal information in a structured,
commonly used and machine-readable format. You also have the right to request
that we transfer it to another party, with certain exceptions. We will provide
further information to you about this if you make such a request.
Correction
You have the right to correct any of your
personal information we hold that is inaccurate. You can access the personal
information we hold about you by logging into your Game account. If you believe
we hold any other personal information about you and that information is
inaccurate, please contact us
at https://www.pubgmobile.com/datasubject.
Erasure
You can delete your account, or remove certain
personal information, by logging into your account. If there is any other
personal information you believe we process that you would like us to erase,
please contact us at https://www.pubgmobile.com/datasubject.
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 Game
Services and there are grounds for erasure, we will use reasonable steps to try
to tell others who are displaying the personal information or providing links
to the personal information to erase it too.
Restriction of Processing to Storage Only
You have a right to require us to 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). As above, where we agree
to stop processing the personal information, we will try to tell any third
party to whom we have disclosed the relevant personal information so that they
can stop processing it too.
You have the right to object to our processing of your
personal information. We will consider your request in other circumstances as
detailed below by contacting us
at https://www.pubgmobile.com/datasubject.
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
at https://www.pubgmobile.com/datasubject. 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.
Email
Opt-out
You may choose to stop receiving game update emails
from us by following the unsubscribe instructions included in these emails or
you can contact us at service@pubgmobile.com.
SMS
Opt-out
You may opt out of receiving game update
marketing or advertising text messages by contacting us at service@pubgmobile.com, and sharing the phone number that you would like to
opt out. For text messages, you also may be able to text “STOP” in response to
a text message that you receive.
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 Game for maintenance, or security, privacy or
administrative-related communications). You may not opt-out of these
service-related announcements, which are not promotional in nature.
We welcome questions, comments and
requests regarding this privacy policy. Please address them to dpo@proximabeta.com.
In the event that you wish to make a
complaint about how we process your personal information, please contact us in
the first instance at dpo@proximabeta.com and we will endeavour to deal with your request
as soon as possible. This is without prejudice to your right to launch a claim
with the data protection authority in the region in which you live or work
where you consider we have infringed data protection laws.
If we make any material changes to this
privacy policy, we will post the updated policy here and notify our users
within the Game. Please check this page frequently to see if there are any
updates or changes to this privacy policy.
9. Language
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.
SUPPLEMENTAL
JURISDICTION-SPECIFIC TERMS
Some jurisdictions’
laws contain additional terms for users of the Game Services, 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 Game Services, you
give us your consent for the collection, storage, treatment and use of your
personal information, and transfer of your personal information to a third
party (such as local cloud providers to back up your data or our affiliates
around the world to help us deliver the Game Services) located in Singapore and
the United States of America (as described in the Privacy Policy) where it is manually and electronically treated.
Argentina
Your rights
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).
Data transfers
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 us
your personal information and by using the Game Services, 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.
Australia
Overseas Recipients
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.
Access
You have the right to access personal
information we hold about you, how we use it, and who we share it with. You can
access the personal information you have made available as part of your account
by logging into your account. If you believe we hold any other personal
information about you, please contact us at dpo@proximabeta.com.
Correction
You have the
right to correct any of your personal information we hold that is inaccurate.
You can access the personal information we hold about you by logging into your
Game account. If you believe we hold any other personal information about you
and that information is inaccurate, please contact us at dpo@proximabeta.com.
Children
If you are under the age of 18, you
undertake that you have the consent of your parent or legal guardian to
register an account on and use the Game Services.
Transacting Anonymously
Where
practicable, we will give you the option of not identifying yourself or using a
pseudonym when registering an account on or using the Game Services. 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
Game Services, including social media integration and in-Game purchases.
Your Rights
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).
Data Transfers
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.
Bangladesh
Agreement
By accepting this 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
this Privacy
Policy. By
clicking the button to proceed, you consent to the cross-border transfer of
your information to any country where we have databases or affiliates and, in
particular, to Singapore
and the United States.
Age Restriction
In order to use the Game Services, you represent that you are
at least 18 years old and, therefore, legally capable of entering into binding
contracts.
Brazil
This section applies to users located in
Brazil:
Language
This privacy policy is provided in
Portuguese for users located in Brazil. In case of dispute, the Portuguese
version of this privacy policy shall prevail.
Consent Revocation
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 at https://www.pubgmobile.com/datasubject.
This may affect our provision of the Game Services to you.
Parental and Guardian Consent
If you are under the age of 18, you should
not use the Game Services for any purpose without first obtaining
parental/guardian agreement to this privacy policy (both for themselves and on
your behalf). We do not knowingly collect personal information from any
children under the age of 18 without such consent. Please contact our Data
Protection Officer if you believe we have any personal information from any
children under the age of 18 without such parental/guardian consent – we will
promptly investigate (and remove) such personal information.
BY ACCEPTING THIS PRIVACY POLICY, YOU
EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR
PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES AND TRANSFERRING
TO COUNTRIES OTHER THAN BRAZIL, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.
California
This section applies to California residents covered by the California
Consumer Privacy Act of 2018 (“CCPA”).
Collection and Disclosure of Personal
Information
Over the
past 12 months, we have collected and disclosed the following categories of
personal information from or about you or your device:
We collect your personal information for the
following purposes:
For additional information
about what each type of personal information is used for, see this chart in the main portion of the privacy policy.
We disclose personal information to the following
types of entities:
In the
past 12 months, we have not sold Personal Information of California residents
within the meaning of “sold” in the CCPA.
Rights under the CCPA
If you are a California resident, you have
the right to:
We aim to fulfil all verified requests within 45 days
pursuant to the CCPA. If necessary, extensions for an additional 45 days will
be accompanied by an explanation for the delay.
How to Exercise Your Rights
First, you may wish to log into your account and
manage your data from there. If you
are a California resident to whom the CCPA applies, you may also exercise your rights,
if any, regarding other data by contacting us at
https://www.pubgmobile.com/datasubject.
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 at dpo@proximabeta.com. Our
privacy experts who monitor this email address are also able to answer any
questions users may have about the collection, use, disclosure or storage of
personal information by our service providers.
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
Language
This
Privacy Policy is provided in Spanish for users located in Colombia. In case of
dispute, the Spanish version of this Privacy Policy shall prevail.
How We Use Your Personal Information
From the entry
into force of this Privacy Policy, at the time of the collection of your
personal data, we will request your prior authorization, by informing you about
the specific purposes of the processing of your personal data for which such
consent is obtained under the Privacy Policy.
Your authorization
may be expressed (i) by writing, (ii) orally or (iii) through unequivocal
conducts that allow us to reasonably conclude that your authorization was
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.
Your Rights
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 if you want to exercise any of these
rights through our contact information in the section ‘Contact &
Complaints’ of this Privacy Policy.
Proceedings For The Exercise Of
Your Rights
Queries (rights to access): You can file queries regarding
the processing of your personal data by us.
Claims (right to correction and erasure): You have the right
to file claims in relation to the processing of your personal data by clearly
describing the facts that give rise to your claim.
Egypt
This privacy policy is provided in Arabic for users
located in Egypt. In case of dispute, the Arabic version of this privacy policy
shall prevail.
By clicking the button to proceed or by proceeding
with the sign up process, you acknowledge that you have read, understood, and
consented to this privacy policy. If you do not consent to this privacy policy,
you must not use the Game Services.
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 Singapore, Indonesia, the People’s Republic of China and the
United States.
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
Your Rights
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 at dpo@proximabeta.com.
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 reject to the use of your personal data for direct
marketing purposes. A fee may be chargeable by us for complying with a data access request.
India
Age Restrictions
Parental consent is required for children
under the age of 18 years to use our services.
Sensitive Personal
Information
Sensitive Personal Information under local
law includes passwords, financial information (such as bank account, credit
card, debit card or other payment instrument details), biometric data, physical
or mental health, sex life or sexual orientation, and/or medical records or
history, but does not include information available in the public domain, or
provided under Indian laws, including the Right to Information Act, 2005.
Sharing Of Your
Sensitive Personal Information
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 the Sensitive Personal Information to
the extent required by applicable laws.
Withdrawal Of Consent
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 at
https://www.pubgmobile.com/datasubject. 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.
Indonesia
Consent
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.
Parental and Guardian
Consent
If you
are under the age of 21, you undertake that you have the consent of your parent
or legal guardian to register an account on the Game and use the Game Services.
Data Subject Rights
You
have the right to access your personal information stored in our Game from time
to time in accordance with applicable data privacy laws and regulations in
Indonesia.
Data
Breach
In the
event we fail to maintain the confidentiality of your personal information in
the Game, we will notify you through the contact information provided by you or
via the Game, to the extent required by local laws and regulations.
Data Retention
We
will retain your personal information in line with legal requirements.
Notification to Amendment
of this Privacy Policy
If you fail to explicitly
express your objection to any amended version of this privacy policy within
fourteen (14) days of the date the relevant amended version of this privacy
policy is made available , you will be considered as having accepted the
changes and agreed to the new privacy policy. However, you may stop using or
accessing our Service by unsubscribing or ceasing your use of the Game Services
at any time, if you cease to agree with the amended privacy policy.
Data Accuracy and Third
Party Consent
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).
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.
Kuwait
You
represent that you are at least 21 years old, or 18 years old and have obtained
parental/guardian consent and, therefore, legally capable of contracting under
the applicable laws and regulations in 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.
Macau SAR
You
have the right not to provide your personal information. However, as a result,
we may not be able to provide the Game Services to you. As a Macau SAR 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, or on any grounds of personal nature. A fee may be chargeable by
us for complying with a data access request.
Malaysia
Parental and Guardian Consent
If you are under the age of
18, please do not use the Game Services.
In the event you are
agreeing to this privacy policy in order for a minor to access and use the Game
Services, you hereby consent to the provision of personal information of the
minor to be processed in accordance with this privacy policy and you personally
accept and agree to be bound by the terms in this privacy policy. Further, you
hereby agree to take responsibility for the actions of such minor, and that
minor’s compliance with this privacy policy.
Your Rights
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 requestor 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 requestor 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 Game Services to you.
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.
Mexico
Language
This
Privacy Policy is provided in Spanish for users located in Mexico. In case of
dispute, the Spanish version of this Privacy Policy shall prevail.
Age Restrictions
Please
do not use the Game Services unless you are 18 years old or you have obtained
parental/guardian agreement to this Privacy Policy (both for themselves and on
your behalf).
Types of Personal Information We Use
For
clarification purposes, in section "The types of personal information we
use” and section “How we use your personal information” you can find full
details about the personal data we use. Therefore, we are providing you with
complete information about the personal data we use, in terms of the Federal
Law on Protection of Personal Data held by Private Parties and other applicable
regulations.
Purposes of Processing
Some
of the purposes of processing stated above are for voluntary purposes,
including to show you personalised recommendations. We may also use your
personal data for the voluntary purpose of sending information to your email or
SMS that we may consider relevant to you. You may object to the processing of
your personal data for voluntary purposes as stated in the section “Your
Rights” below.
Please
be informed that we may also use your personal data to comply with legal
obligations or requests from competent authorities, assert or defend our rights
before the competent authorities / courts, respond to requests you send us in
relation to your personal data and carry out the transfer of personal data
detailed in section “How we store and share your personal information”.
Data Transfer Consent
In
general, we do not require your consent to carry out the transfers detailed in
section “How we store and share your personal information”. However, we require
your consent to transfer your personal data to a third party that acquires all
or substantially all of us or our business.
By
using the Game Services and providing us with your personal data, you agree to
the data transfers detailed above that require your consent. You may exercise
your rights in connection with your personal data as stated in the section
“Your Rights” below.
Your Rights
The
sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”,
“Restriction of Processing to Storage Only”, which include limitation to the
use and disclosure of your personal data, and “Email Opt-Out” and “SMS Opt-Out”
included in Section “Your Rights” above also apply to users that are located in
Mexico.
You
also have the right to revoke the consent that you have provided us to process
your personal data.
To
exercise any of your rights, contact our Data Protection Officer at dpo@proximabeta.com.
To
know more about your rights, as well as the applicable means, procedures and
requirements to exercise any of your rights, please contact our Data Protection
Officer at dpo@proximabeta.com.
Cookies
Through
the use of cookies, we collect certain information related to your browsing and
device, some of which may be considered personal data (detailed in our Cookie
policy here). You
may be able to refuse or disable cookies by adjusting your browser settings.
Because each browser is different, you should consult the instructions provided
by your browser. If you choose to refuse, disable, or delete cookies, some of
the functionalities of the Game Services may no longer be available to you. For
more information about our use of cookies and how to disable them, please visit
our Cookie policy here.
Morocco
The protection of your privacy is an
important principle for us. We collect information for purposes strictly
necessary for the proper use of the Game Services.
By accepting these conditions of
use, you explicitly accept that your personal data may be subject to processing
by the Game Services.
Kindly note:
·
the identity of the Data
Controller is Proxima
Beta Pte. Limited, email: dpo@proximabeta.com.
·
the purposes of the
processing for which the data is intended are set out in the table in the
section “How
we use your personal information”.
·
recipients or categories of
recipients are set out in the second paragraph of the section “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 the section “How
we use your personal information”
and the section “Your Rights” (sub-paragraph
“Objection”).
New
Zealand
This section applies to users
located in New Zealand:
Overseas Recipients
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.
Access
You have the right to access
personal information we hold about you, how we use it, and who we share it
with. You can access the personal information you have made available as part
of your account by logging into your account. If you believe we hold any other
personal information about you, please contact us at dpo@proximabeta.com.
Correction
You have the right to request the
correction of any of your personal information we hold that is inaccurate. You
can access the personal information we hold about you by logging into your
account. If you believe we hold any other personal information about you and
that information is inaccurate, please contact us at dpo@proximabeta.com.
Children
If you are under the age of 16,
you undertake that you have the consent of your parent or legal guardian to
register an account on and use the Game Services.
Your Rights
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).
Data Transfers
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, etc. pursuant to applicable laws such as 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.
Upon your request, we will take necessary measures
without delay in accordance with applicable laws such as 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.
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.
Philippines
Minimum Age
You must be at least 18 years of age to be able to use the Game
Services.
Your Rights
You are entitled to the following rights:
Consent
By consenting to this Privacy Policy, you consent to us:
·
collecting and processing your
personal information as described in the section “How We Use Your Personal Information” above;
·
sharing your personal information
with third parties, companies within our corporate group, and a third
party that acquires 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
the section “How We Store and Share Your
Personal Information” above.
Qatar
If you are using the Game Services 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.
Russia
If you are using the Game Services in Russia, this section
“Russia” applies to you. By using the Game Services:
The sub-sections “Access”, “Correction”, “Erasure”, “Restriction
of Processing to Storage Only”, “Objection”, “Email Opt-Out” and “SMS Opt-Out” of the section “Your
Rights” above apply to users in the Russian Federation.
We will notify you of any material changes and may request you to
acknowledge such changes. Unless we require your acknowledgment, you shall be
deemed to have agreed to the changes if you continue using the Game Services
after the notification.
As regards the representative for Russia, you can contact us at
dpo@proximabeta.com. Please include the word “Russia” in the subject line of
your email.
Separate
consent for using certain data
For the purposes of the operation of the Service, as part of its
activities, we do not distribute (publicly disclose) personal data without the
appropriate consent of the data subject and in compliance with the requirements
of Article 10.1 of Russian Federal Law No. 152-FZ dated 27 July 2006 “On
Personal Data” (as amended).
By using the Game Services you also consent to the sharing of your
personal information with certain third parties for the purposes set out under
section “How We Store and Share Your
Personal Information”.
You determine, in your discretion, the terms of disclosure to the
general public of your personal data, by choosing to use certain features of
the Game Services and by choosing the appropriate privacy settings in respect
of your personal information in the Game Services.
We process your personal information subject to the terms of this
Privacy Policy and your chosen features and settings.
This consent is granted for as long as you use the Game Services.
The consent may be withdrawn by you (and you may set any restrictions on
processing of your relevant personal information) at any time by contacting us
(dpo@proximabeta.com): please include the word “Russia” in the subject line of your
email.
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.
Singapore
By clicking the button to proceed, you consent to the cross-border
transfer of your information to any country where we have databases or
affiliates and, in particular, Indonesia, the People’s Republic of China and
the United States.
Access
You have the right to access your personal
information, how we use it, and who we share it with. You can access the
personal information you have made available as part of your account by logging
into your account. If you believe we hold any other personal information about
you, please contact us at
https://www.pubgmobile.com/datasubject.
Correction
You have the right to correct any of your
personal information that is inaccurate. You can access the personal
information we hold about you by logging into your account. If you believe we
hold any other personal information about you and that information is
inaccurate, please contact https://www.pubgmobile.com/datasubject.
Our designated data protection officer for the purposes of compliance with
the Personal Data Protection Act 2012 can be contacted at dpo@proximabeta.com.
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
the button to proceed, you consent to the terms and conditions of 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 register an account on and
use the Game Services.
Where you
request to withdraw consent, refrain from further processing of data, erase, rectify
or complete your personal information, we will provide you with our response to
the request within 21 working days.
Thailand
By accepting this privacy policy, you acknowledge that you have read,
understood, and agree to this privacy policy. If you do not agree with this
privacy policy, you must not use the Game
Services.
You may request us to discontinue, to restrict the use or provision of,
and/or to request for data portability of any and all of your personal
information which is stored by us, to the extent provided by the Act on the
applicable data privacy laws and regulations in Thailand, including the Thai
Personal Data Protection Act. When you wish to make such requests, please
contact us at https://www.pubgmobile.com/datasubject.
We will give you notice of any material changes to this privacy policy, and
give you an opportunity to reject such changes, failing which the changes will
become effective as stated in the notice.
Turkey
Our Data Controller Representative in
Turkey for the purpose of compliance with Turkish Law on Personal Data
Protection Law (“DPL”) and its
secondary regulations, Özdağıstanli Ekici Avukatlık Ortaklığı, can be contacted
at turkeydatarep_proximabeta@iptech-legal.com. Please include the word “Turkey” in the subject line
of your email.
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):
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 |
|
Aceville Pte. Ltd. |
Singapore |
Storage of personal information |
All personal information as set out in the section “How We Use Your
Personal Information’ |
|
|
|
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 other than Ukraine, to the extent and for
the purpose provided by this Privacy Policy.
United Arab Emirates
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 the privacy policy.
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.
IN-GAME CHAT SAFETY FUNCTION
1. Introduction
We take
your data privacy and security very seriously. We take steps to ensure that
your content is stored and processed by us in a transparent way and using
secure and reliable technology.
We
understand that your trust is something we earn. As part of that process, we
work to keep you informed of our data privacy policy and measures, as they may
change over time.
This
FAQ explains some common questions on a feature for certain regions concerning
chat of PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE (“Game”), particularly for those users
and prospective users who have questions about how we meet our requirements
under data protection laws and other applicable regulations concerning data
privacy.
For
further information regarding our data privacy practices and this FAQ:
(a)
Please review the PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE Privacy Policy
– which sets out how we collect, store and process your personal data to
provide you with the Game, and the End-user License Agreement
for PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE.
(b)
Please contact our privacy team via email at dpo@proximabeta.com should
you have any further questions.
2. What is the in-game chat safety function?
To
ensure the Game provides a safe platform for users of the Game, we have
introduced an in-Game chat safety function (“Safety Feature”) in certain regions. The Safety Feature helps us to
improve your experience of the Game by flagging users who use chat function in
violation of our End-user License Agreement.
For countries where the law requires that we have a legal basis for processing
certain data, we operate the Safety Feature in our legitimate interests to
ensure the safety and integrity of our Game. The Safety Feature works to
identify, for example, unsolicited commercial communications, including plug-in
sales and advertising, spam, harmful communication, exploits, bullying,
harassment, threats of violence or conduct which is hateful, harassing,
abusive, racially or ethnically offensive, defamatory, humiliating,
threatening, profane or similarly objectionable (“Prohibited Conduct”).
3. What are the consequences for users who engage in
Prohibited Conduct?
All
users are required to comply with our End-user License Agreement,
and you should familiarize yourself with your obligations as part of our gaming
community. In order to ensure a safe gaming environment for our users we may
take action against users who violate the End-user License Agreement or otherwise
engage in Prohibited Conduct, which may include limiting use of those features
that have been abused.
4. How can I use the Safety Feature and how does it work?
When
you observe a user engaging in Prohibited Conduct, you can press the “Report”
button on the screen if this feature is available in your region. This will
record a short snippet of the chat and convert it into text at the same time.
The text may be automatically translated if needed. Please note that the Safety
Feature is only available on Spawn Island before the battle begins while
playing the Game’s classic game mode.
5. What if I think I have been implicated by mistake?
We have
implemented safeguards to ensure any consequences are appropriate and
proportionate to the relevant Prohibited Conduct and the frequency with which
such Prohibited Conduct has occurred.
We will
notify you if you have been muted, as a result of your breach of the End-User License
Agreement. If you think your account was muted by
mistake, please contact us at service@pubgmobile.com to
request a review.
6. Do you warn users before taking action?
We may
not issue a warning before muting you but we will notify you if you have been
muted.
7. Do you store chats and where do you store them?
The
Safety Feature is designed to protect your privacy. Documented version of the
chat is not stored, except where it provides evidence of Prohibited Conduct by
a user. In these cases we store the clip and documented version of the chat as
evidence on our servers in the United States and Singapore and subsequently
automatically delete it in accordance with our Privacy Policy.
8. Do you share chats with any third parties?
We do
not share any chats of any user with any third party, except where necessary
for the translation process or in exceptional circumstances, such as where we
believe we are legally required to (for example, if we are subject to a court
order for disclosure), or where we need to do so in order to enforce or protect
your rights, our rights or the rights of other users. Please consult our Privacy Policy
for further details.
9. Can I object to your processing of my chats?
Yes. If
you are a resident of a relevant country as noted in our Privacy Policy,
you may have the right to object to, and seek restriction of, our processing of
your chats for this purpose. To exercise your right, please contact us at dpo@proximabeta.com
and please consult the Privacy Policy
for further information.
We will
consider several factors when assessing an objection, including: our users'
reasonable expectations; the benefits and risks to you, us, or other users as a
result of our implementation of the Safety Feature; and other available means
to achieve the same purpose the Safety Feature achieves that may be less
invasive and do not require disproportional effort. Unless the processing is based
on our compelling legitimate grounds or is needed for legal reasons, your
objection will be upheld and we will cease processing your information.
10. Is the Safety Feature secure and how do you comply
with data protection laws?
We have
a comprehensive global privacy program directed at protecting your personal
data. You can read about how we process and protect personal data in our Privacy Policy.
We also use a variety of security technologies and procedures for the purpose
of preventing loss, misuse, unauthorized access or disclosure of your
information.
11. How do you respond to law enforcement requests for
chat information?
We may,
from time to time, receive law enforcement requests to disclose your chat
information (and its translation) to regulators, courts or law enforcement
bodies. When we receive these requests, we take reasonable steps to query them
and establish whether or not we are legally required to respond to them. When
we are legally required to respond to such a request, we will take measures to
safeguard your legal rights and your personal data.