Privacy Policy

INTRODUCTION

If we should at any time choose to provide you with a translation of the English language version of this Privacy Policy, you agree that such translation is provided for your information only and does not amend this English version. In the event of any conflict between a translation of this Privacy Policy and the English version, the English version shall prevail.

We recognize that persons who access and/or use (“you” or “Users”) our games, whether played on our website, on mobile devices, PCs, or on other platforms (“RAIWON SOFT”) and other related services, including but not limited to customer supporting, marketing and advertising, (collectively, the “Services”) value their privacy.

This Privacy Policy provides important information regarding:
i) the data collected from you and the ways we collect your data,
ii) the reasons why we collect your data,
iii) to whom we disclose your data, and
iv) the options you have about your personal data.

Unless stated otherwise, this Privacy Policy applies to the Services and all data that we collect from you. We therefore provide this Privacy Policy to help you make an informed choice about whether to use or continue using our Services. We may periodically update this Privacy Policy by posting a new version on our website. Your continued use of the Services after the effective date will be subject to the latest version of the Privacy Policy.

This Privacy Policy is incorporated into, forms part of, and is subject to the Terms of Service. Your use of the Services and any personal information you provide on the Site is subject to the terms of this Privacy Policy and the Agreement.

Any terms not defined herein but defined in the Terms of Service shall have the meaning ascribed thereto in the Terms of Service.

Ⅰ. THE DATA COLLECTED FROM YOU AND THE WAYS WE COLLECT YOUR DATA

1. Data provided by you
To use the Services, you may directly provide certain personally identifiable information to us, such as:

• Contact information (e.g. your name, personal identification number, postal or e-mail address, telephone numbers)
• Registered username and password
• Character Information (e.g. Account ID, character name, profile picture. Please be reminded that such information may be disclosed to other users in connection with the use of the Services and may also be made available to your connections or the public on third-party services)
• Personal content preferences
• Profile information (e.g. profile photo)
• Messages to the Services (e.g. chat logs, your support tickets)
• Billing and financial information (Please be reminded that the use of any merchant service provider and/or third-party platforms for the payment of the Admission Fee is subject to the privacy policy of the relevant merchant service providers and/or third-party platforms)
• Other data that you voluntarily provide (e.g. data to identify a lost account)

2. Data collected automatically
When you access our Website or use the Services, we may use cookies and/or other similar technologies. Cookies are small text files stored by browser(s) on your desktop computer or mobile device. Most web browsers automatically accept cookies, but you can usually modify browser settings to decline cookies. If you choose to decline cookies, you may not be able to access certain Services and may experience technical problems receiving current information from the cookie-disabled services. The use of cookies and/or other similar technologies is to identify your browsers and to collect data from your device, such as:

• Data about your Account
• Internet Protocol (IP) address, web request, domain name, URLs, referring/exit pages, platform type, and mobile device identifiers (e.g. your device ID, advertising ID, MAC address, IMEI)
• Data about your device (e.g. device name, operating system, browser type, and language)
• Data we collect with cookies and similar technologies
• Monitoring of aggregate metrics (e.g. total number of visitors, pages viewed, usage of the Services)
• General location data
• Precise geo-location data (i.e. GPS)
• Data about your use of the Services (e.g. number of clicks, landing pages, pages viewed and order of those pages, the amount of time spent on particular pages, the date and time of your request, your gameplay and activity, your game progress, your interactions with other players inside the Services)
• Other pieces of information in connection with your various activities within or through the Services or otherwise that are sent by your browser, device, or computer system when you access the Services, which are automatically tracked and recorded by our servers.

3. Data collected from our partners
When you access the Services through any third-party services such as social networking sites (e.g. Facebook, WeChat, Google) or from any mobile devices, you allow us access to certain information stored on these third-party services or mobile devices such as:

•   Demographic data (e.g. determination of your IP address)
•   Data to fight against fraud (e.g. refund abuse in games or click fraud in advertising)
•   Data from platforms that the games run on (e.g. verification of payment)
•   Data associated with your device (e.g. device type, technological information, telephone number, country, contacts)
•   Data to do advertising, marketing, and analysis

4. Data Retention Policy in Korea
We collect, use, and store your personal data according to your consent and relevant laws and regulations for purposes set out in the Privacy Policy. In principle, we will destroy your data without delay after the above-mentioned purposes are achieved or the retention period expires.

In accordance with the "Act on Promotion of Information and Communications Network Utilization and Information Protection, Etc." and the "Enforcement Decree" of the same Act, we agree to protect the personal data of long-term-inactive-users (hereinafter referred to as “dormant accounts”) who have not used the Services for the past one year. We will take necessary actions, such as the destruction of personal information. In this case, you may be notified of the fact that necessary actions will be taken 30 days before they happen, the retention periods for different records expire or the purpose of data collection is achieved. If you wish to continue using the Services, we advise you to log in within one year from the last login date.

In addition, your personal data will be retained for 30 days after you request to withdraw it or delete your account to prevent any theft of your personal data or account.

Notwithstanding the preceding paragraphs, even if the purpose of data collection has been achieved, if there is a need to preserve it according to the following provisions, we will keep your information for a certain period of time as provided by relevant laws and regulations. In this case, we use the stored information only for the purpose of storage, and the retention period of different information is listed as follows:

4.1 Records of visits and information related to service use
- Retention period: 3 months
- Legal ground: “Communication Secret Protection Act”

4.2 Login information
- Retention period: 1 year
- Legal ground: "Act on Promotion of Information and Communications Network Utilization and Information Protection, Etc."

4.3 Legal grounds of the following records: "Acts on Consumer Protection in Electronic Commerce, Etc."
4.3.1 Records on display/advertisement:
- Retention period: 6 months
4.3.2 Records on contract or subscription withdrawal:
- Retention period: 5 years
4.3.3 Records on payment and supply of goods:
- Retention period: 5 years
4.3.4 Records on handling consumer complaints or disputes resolution:
- Retention period: 3 years

4.4 Books and supporting documents for all transactions stipulated by the tax law
- Retention period: 5 years
- Legal ground: "Framework Act on National Taxes"

Ⅱ. THE REASON WHY WE COLLECT YOUR DATA

1. To provide the Services  
To provide the Services, we process data necessary to

• Create Accounts
• Allow you to play RAIWON SOFT and use the Services
• Operate the Services
• Verify and confirm payments
• Provide and deliver products and services that you request
• Send service-related communications to you

2. To improve and optimize the Services
To provide better Services to you, we have a legitimate interest to collect and process the necessary data to

• Update and develop the Services
• Manage and update your Account
• Develop and improve your experience
• Manage the relationship with you
• Provide social features to you
• Customize your service experience
• Respond to your comments and questions and provide support to you
• Provide offers in the Services as well as in other websites and services
• Send related information (e.g. updates, security alerts, support messages) to you
• Enable you to communicate with other users

3. To carry out activities related to advertisements and marketing
To send you personalized advertising and marketing materials, we may use the information collected from you, such as ad identifiers, age, country, region, gender, language, games played by you, information related to your interaction with the Services and with other users, and so forth.

We may also use various third-party advertising and marketing partners to assist us on our behalf. We may share information collected from you with such third parties for this purpose.

Hence, we have a legitimate interest to process the necessary data to

• Track the content you access in connection with the Services and your online behavior
• Deliver, target, and improve our advertising and marketing materials
• Pass the information collected from you to third-party advertising and marketing partners

By accepting this Privacy Policy and downloading or continuing to use the Services, you consent to us and our advertising and marketing partners collecting and using information about you to personalize advertising and marketing materials and to improve your experience unless you opt out of receiving this service.

We encourage you to review the privacy policies of our third-party advertising and marketing partners so that you can understand how these third parties collect, use, and share your information. We are not responsible for the privacy policies of any third party, whether accessed through the Services or otherwise.

For information on how to opt out of receiving personalized advertising and marketing materials, see the section 'The options you have about your personal data' below.

4. To secure the Services
Ensuring security while performing the Services is a top priority for us. We take appropriate security and technical measures to protect your information from unauthorized access, loss, and misuse. To achieve this purpose, we also request that our suppliers who process personal information on our behalf take appropriate security measures.

In order to keep the Service and its social features safe and fair, to fight fraud, and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

• Analyze and monitor use of the Services and its social features
• Moderate and monitor chats
• Prevent cheating, crime or fraud
• Take action against fraudulent or misbehaving users
• Pass your information to agencies or organizations in charge of crime and fraud prevention and repression

Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any of the communication facilities provided by us. We recommend that you exercise caution when disclosing any information through the Services. In particular, please note that others may collect and use any personally identifiable information or personally sensitive data that you communicate or disclose to any user in connection with the Services. As such, you should take care of the information shared online. Please also be reminded that any questions, answers, comments, or submissions that you post in the forum will be publicly available.

5. To analyze, research and test
In all of the above cases and purposes, we may use analytic tools, including third-party tools, to carry out research, surveys, and analysis, create reports for use, track potential problems with the Services, or test out new game features and content.

6. To obtain your consent
With your consent, we may process personal data for additional purposes.

Ⅲ. TO WHOM WE DISCLOSE YOUR DATA

1. Our personnel, related or affiliated companies
We may provide your personally identifiable information and non-personally identifiable information to our personnel and related or affiliated companies for our legitimate business purposes. We may also provide your personally identifiable information and non-personally identifiable information to other businesses or persons for the purpose of processing such information or otherwise assist us in performing any services on our behalf, including in any advertising and marketing activities. We require that these parties agree to process such information in compliance with our Privacy Policy contained herein, and we will use reasonable efforts to limit their use of such information and to use other appropriate confidentiality and security measures.

2. Other users
As social features are a core element of our games, other users may see your profile data and in-game activities and read the messages you have posted.

Any user who receives any information, including personally identifiable information, from another user shall not disclose or use such information, save where expressly permitted by that user, or save where such information has ceased to be of a confidential nature. In any event, we shall not be liable for any unauthorized disclosure or use by another user or other person of any content.

3. Partners working for us
To strengthen the functions of our Services and your experience of use, some of our Services may be provided by partners in charge of advertising, payment, analysis, marketing, social media partners, personalized services, and/or personalized push notifications and recommendations. To the extent of the law and for the purposes of advertising, payment, statistical analysis, marketing, personalized services, and/or personalized push notifications and recommendations, we may share with these partners your data, including but not limited to your device information, such as its device brand, device manufacturer, device platform and device ID number, your applications list, internet information, and GPS location information, that you have consented to our collection. In addition, these partners may also access your data when you use their services and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices. 

4. Other companies and public authorities
We may release personally identifiable information and/or non-personally-identifiable information to, exchange such information with companies and organizations, or provide such information to public authorities if required to do so by the law or in the good faith belief that such action is necessary to comply with all and any applicable laws, or where it is pursuant to or we are required to respond to a governmental, regulatory, administrative or court order or directive, a subpoena or a search warrant, or to combat fraud and illegal activity.

We also reserve the right to disclose personally identifiable information and/or non-personally-identifiable information that we believe, in good faith, is appropriate or necessary to enforce the Agreement, take precautions against liability, investigate and defend against any third-party claims or allegations, to assist government authorities and enforcement agencies, to protect the security or integrity of the Services, and to protect the rights, property, or personal safety of ourselves, our users or others.

Your data will not be disclosed to a third party unless such disclosure is agreed to by you or approved by relevant laws such as the Personal Information Protection Act.

Ⅳ. THE OPTIONS YOU HAVE ABOUT YOUR PERSONAL DATA

1. Opt out of advertising and/or marketing materials
You may opt out of receiving advertising and/or marketing communications by following the instructions in such communications or by using options provided in the settings in the game or on your devices.

2. Access and correct the personal data we hold about you
You have the right to access and correct your personal data.

3. Other rights
You also have the right to delete your personal data, object to how we use or share your personal data, and restrict how we use or share your personal data. You can always withdraw your consent.

If you decide to delete your account or remove certain of your personal data, provided that such removal request will not affect our provision of Services, you can contact us through the contact information listed in Section XI. 

If the purpose of collecting and using your personal data has been achieved and the relevant data retention period expires, we will destroy your relevant data without delay according to relevant local laws.

Personal data will be destroyed according to the following methods:
　i) Personal data stored in the electronic form will be permanently deleted using a technical method that makes such deleted personal data irrecoverable or irreproducible;
　ii) Personal data printed in hard copy will be destroyed by shredder.

If you have questions about data protection or any requests to resolve issues with your personal data, we encourage you to primarily contact us through the game so we can reply more quickly. Alternatively, you can contact us through the contact information set out in Section XI of the Privacy Policy. We will respond to all requests within a reasonable time frame.

4. Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.

Ⅴ. INTERNATIONAL DATA TRANSFERS

By accepting this Privacy Policy, Users understand and agree that your data may be collected, stored, used in any country, and/or transferred to any country in the world. Because different countries may have different data protection laws than Users’ own country, we will try to ensure that adequate safeguards are in place to protect Users’ data.

For users located in the Republic of Korea, you may know the details about where and how we store or transfer your personal data to a country/region other than the Republic of Korea.

If you want to refuse or withdraw your consent to transfer your data outside of the Republic of Korea, you can apply through the contact information listed in Section XI. However, in this case, our Services that necessarily involve transferring personal information overseas will be affected and you will not be able to use our Services properly.   

Ⅵ. SPECIAL NOTE TO INTERNATIONAL USERS

The use of the Website and Services and this Agreement is governed by and shall be construed and enforced under the laws of Singapore without applying any conflicts of law principles that would require the application of the law of any other jurisdiction. You agree to submit to the personal, non-exclusive jurisdiction in Singapore and any other court of competent jurisdiction chosen by us.

In the event of any dispute arising out of or in connection with this Agreement, including any question regarding its existence, validity, or termination (a “Dispute”), we strongly encourage that a resolution first be sought through our Customer Support service.

You agree that in the event that a resolution is not obtained through our Customer Support service, such Dispute shall be referred by you and may be referred by us to and finally resolved by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause. The Tribunal shall consist of three (3) arbitrators, with you appointing one (1) arbitrator and us appointing one (1) arbitrator and the third arbitrator to be selected by the two (2) arbitrators so appointed. The language of the arbitration shall be English.

Notwithstanding any of the foregoing, you agree that we are entitled to submit such Dispute for resolution through any other dispute resolution mechanism, including the courts of any jurisdiction, and we shall further be entitled to seek any injunctive or other equitable relief in the event of any breach or anticipatory breach by you without any obligation to provide any bond or surety or proof of damages.

You irrevocably waive all rights to seek any injunctive or other equitable relief or to enjoin or restrain the operation or exploitation of the Services or any part thereof. You further irrevocably waive all rights to a class or representative action or as a named or unnamed member in a class, consolidated, representative or private attorney general action.

Ⅶ. OUR POLICIES CONCERNING CHILDREN

The Services are not intended to be accessed by persons under the age of majority without permission of their parent(s) or legal guardian(s). In particular, we do not knowingly collect or solicit personal data from persons under 14 years old without permission of their parent(s) or legal guardian(s). In the event that we learn that we have inadvertently gathered personally identifiable information from persons under 14 years old, we will take commercially reasonable measures to ensure that such information is removed from our records.

Parents or legal guardians have the following options to safeguard the personal information of their children under 14 years old:

1. Access personal information；
2. Revise errors in personal information；
3. Delete personal information；
4. Suspend processing of personal information；
5. Withdrawal of consent.

You can contact us through the contact information listed in Section XI to submit these requests or ask us any other questions you may have about how we handle your child’s personal information. 

Ⅷ. DATA SECURITY

We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. However, we cannot ensure or warrant the security of any information you disclose on, through, or within the Services, and you do so entirely at your own risk. Please note that we cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on the Website if a security breach occurs.

Ⅸ. MERGER, ACQUISITION, SALE OR INSOLVENCY
1. In the event that we are acquired by or merged with another entity, we reserve the right, in any of these circumstances, to transfer the information or assign our rights to the information that we have collected from our Users as part of such merger, acquisition, sale, or other change of control.

2. In the event of our insolvency, reorganization, receivership, winding-up, or assignment for the benefit of creditors or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.

Ⅹ. HANGES AND UPDATES TO THIS PRIVACY POLICY
1. This Privacy Policy may be revised, amended, or modified periodically. Please revisit this page to stay in touch with any changes. Your access to the Services signifies your acceptance and agreement to this Privacy Policy (as may be amended or revised from time to time).

2. For questions about our privacy policy, please submit your questions to kerorogunshooting@gmail.com If you would like to change, modify or update the personal information that you have provided in relation to your Account which you registered with us or pursuant to your access to the Services through your account with any third-party service, please submit the request at kerorogunshooting@gmail.com

ⅩⅠ. CONTACT US
If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, then there are several ways of contacting us:

1. via email to support kerorogunshooting@gmail.com; or

Mr. Harry is designated as the Data Protection Officer in charge of personal data protection matters. If you have any questions or concerns related to your personal data, please email to harry@raiwon.com.

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