PangSky Corporation Privacy Policy
PangSky Corporation (“we” or “us”) collects, stores, and uses personal information of its
users (“you”) as a data controller in connection with and in order to provide and develop
our products, mobile applications, services, websites as well as other services (collectively
“Services”) to ensure the highest quality service is provided to you.
In order to prevent any improper use of your valuable personal information, and in the
interest of clarifying the purpose, methods, and scope of its collection and use of your
personal information, we have established this privacy policy (“Privacy Policy”), and
collect, store, and use your personal information according to this Privacy Policy. This
Privacy Policy applies to any person or entity that uses our Services, except to a resident
of the Republic of Korea. If you are using our Services in the Republic of Korea, please
refer to our Privacy Policy in Korean.
All PangSky Services are governed by this Privacy Policy, and by using or accessing a
Service you give consent to the processing, use, and disclosure of your personal
information. Please do not install or use the Services if you do not agree to this
Privacy Policy.
We reserve the right to modify this Privacy Policy, which may be updated from time to
time in accordance with changes in relevant laws and regulations and/or our internal
policy. Your continued use of Services will constitute your acceptance of the changes to
this Privacy Policy.
1. Personal Information We Collect
1.1 At the time of user registration and use of the Services, the information listed below
may be collected and used by us for purposes of maintaining the continuity of Services
and providing appropriate customer assistance:
A. User ID, game version information, and device information (model name, OS version
information, available memory and hard drive capacity, device identification number, IP
address, language, and country settings);
B. If the Services are connected to third party platforms such as SNS, chat services, etc.,
then the user ID, nickname, contact information such as friends list, profile pictures, for
such third party platforms(third party information is used only temporarily and is not
permanently stored);
C. When you join as a member of our online community, we collect information,
including your e-mail address, password, SNS account information for the purpose of
managing membership-related activities; and
D. Service usage records, login access records, payment records created during the
course of using the Services.
1.2 If you seek to participate in sweepstakes or advertisements, and/or purchase paid
content, all of which are supplementary services that operate primarily based on your
personal information, we will first give notice to you and obtain your consent prior to
collecting and using the information including e-mail and mobile phone number.
1.3 When you purchase Virtual Money and Virtual Goods or when we provide you with
refunds, we may collect your information, including mobile phone number, e-mail
address and purchasing market ID.
1.4 We install and operate certain mechanisms to provide you with services tailored to
your specific interests:
A. We may use cookies that automatically collect personal information in order to
provide you with personally customized services. Cookies are small text files of
information (or Similar information: collectively “Cookies”) sent by the server equipment
(collectively “Server”) used for the operation of an application to your device to be
stored within the device memory. Once this happens and you subsequently run the
same application, the application’s server reads the information provided by the cookie
stored within your device to maintain your preferred settings and to provide customized
services. We use cookies for the following purposes:
i. To analyze your access frequency, visit times, browser history, etc.;
ii. To analyze your preferences and areas of interest;
iii. To conduct research and diagnostics to improve our Services;
iv. To promote your convenience;
v. To prevent fraudulent activities; and
vi. To improve security
You retain the right to accept or refuse the installation of cookies. Therefore, you may
allow the installation of all cookies, request notification for installation of each cookie, or
refuse the installation altogether by configuring the device settings or options
accordingly. However, when you refuse the installation of all cookies, you may not be
able to access or use our certain Services requiring cookies.
B. We may use third party service providers and collect personal information as provided
by the service providers, in order to analyze trends and user behaviors to improve our
Services and develop new Services. You may withdraw your consent by deactivating
such functions in advertising settings of the service providers or the advertising settings
for mobile apps. For more information about their privacy practices and opt-out
possibilities, please visit the links below.
- Facebook、Inc. (Facebook Ads & analytics)
https://www.facebook.com/about/privacy
- Google LLC (Google Ads, analytics & AdMob)
https://policies.google.com/technologies/partner-sites
- Adjust GmbH
https://www.adjust.com/terms/privacy-policy
C. We may use advertising measuring/tracking tools to provide you with services tailored
to your specific interests. You may withdraw your consent by deactivating such
functions in advertising settings on your device.
1.5 You and your legal representatives may refuse the collection and have the right to
withdraw consents you made regarding the processing of personal information at any
time. This withdrawal of consent does not affect the lawfulness of processing or
transfers of your personal information before its withdrawal. If you wish to withdraw
your consent, you can terminate user registration or contact us at our contact
information provided in Section 11.
2. Methods of Collecting Personal Information
We may collect your personal information using the following methods:
A. Information you provided while using our websites or Services;
B. Information received from third parties such as affiliates, business partners, etc.; and
C. Information collected from your network communication information and browser
history.
3. Purpose for Collecting and Using Personal Information
3.1 We may use the collected personal information for the following purposes:
A. User Management - Personal identification when providing contents, verification of
existing registration, verification of age and gender, verification of nationality,
management of delinquent users, monitoring and detecting to deter unauthorized or
fraudulent use of or abuse of Services, performance of contracts, and processing of
disputes;
B. Provision of Services - Processing customer complaints and providing other general
customer services; provision of notices; provision of paid services and details of
payments; supporting cooperative gameplay and community services;
C. Development of New Services and Utilization for Marketing and Advertising -
Provision of Services and additional Services to users, provision of information regarding
new events, improving quality of Services, aggregating anonymized statistical data
regarding Services and any additional Services; and
D. Provision of Auto-function for Adding and Registering of Friends - Provision of
automated functions for adding and registering friends by collecting and using users’
mobile phone numbers and the phone numbers of third parties stored in the users’
mobile devices.
3.2 We process your personal information only when we obtain consent from you,
EXCEPT in any of the following circumstances:
A. When processing is necessary for the performance of contract(s) to which you are
party, or when processing is necessary to take steps at request from you prior to
entering into a contract.
B. When processing is necessary for compliance with a legal obligation to which we are
subject. (Such as following order from government agencies to disclose information
based on laws, etc.)
C. When processing is necessary in order to protect your vital interests or of other
individuals.
D. When it is deemed appropriate to investigate, prevent, and take measures against
illegal acts or suspicious acts.
E. When it is necessary for us to process for legitimate interests pursued by us or a third
party to the extent that it does not infringe on your privacy rights, interests or freedoms.
4. Sharing and Provision of Personal Information
4.1 As a principle, we do not provide your personal information to third parties EXCEPT
under the following circumstances:
A. You have provided your prior consent;
B. Third Party Service Providers – We may use third party service providers, such as
payment gateway companies, platform service companies, analytics and ad serving
companies to assist us in providing or improving the Services. We share your personal
information with these third party service providers in order to receive their
services. These service providers may store your personal information in countries or
regions where do not have the data protection laws at the level that is required in your
country or region. In such a case, we will take measures to protect your personal
information such as entering into a contract regarding data protection. We strictly
evaluate all such third party service providers. We take reasonable steps to ensure that
they have established appropriate and secure information administration and
organizational control systems. We impose binding contractual obligations on such
service providers to comply with applicable laws and regulations regarding the
processing of personal information. We also require that they access your personal
information only to the extent necessary to perform tasks in accordance with our
instructions, and for no other purposes.
C. Mergers and Corporate Transactions – In the event that we undergo business
transitions such as a merger, acquisition, joint venture, corporate divestiture or
dissolution, a sale of assets, or similar transactions, we may share, disclose, or transfer
your information, including personal information, to the other organizations that are
parties to such transactions;
D. Sweepstakes and Promotions – We may share your personal information for any
sweepstakes or promotions you enter in connection with the Services in order to
administer, market, sponsor or fulfill such sweepstakes or promotions as necessary, or as
required by applicable laws, rules or regulations; and
E. Legal Purposes – We may provide your personal information to third parties in cases
where we have a good faith belief that doing so is required by law or in order to
cooperate with regulators or law enforcement authorities. We may also provide your
personal information to third parties in order to protect the rights or property of a third
party or us, including enforcement of our Terms of Service.
4.2 Please note that you may choose to disclose your personal information in the course
of contributing user-generated content to the Services. Any data you disclose in any of
these forums, blogs, chats or the like will become public information, and there is no
expectation of privacy or confidentiality with respect to that information.
4.3 We may store and/or transfer your personal information to our affiliates and partners
in and outside of Republic of Korea, EU/EEA member states and the United States in
accordance with mandatory legislation and this Privacy Policy. In such events, we will
obtain your explicit consent, as we strive to protect your personal information in
accordance with personal information protection laws of your country or region.
5. Collection and Use of Children’s Personal Information
5.1 We do not knowingly collect any personal information from anyone under the age of
13 (under the age of 16 in Europe), unless consent is given by a parent or legal
guardian. If you are under 13 years of age (16 in Europe), please do not send us any
information about yourself, and you should not use or attempt to use our
Services. Some of our Services have age restrictions which may vary depending on
countries, regions, OS, platforms, etc. If you are under the applicable age restrictions,
please do not send us any information about yourself and you should not use or
attempt to use our Services. Please refer to our Terms of Service for further information.
5.2 In the event we learn that we have inadvertently gathered personal information from
children under the age of 13 (16 in Europe), we will take reasonable measures to
promptly delete such information from its records in a secure manner. If you believe
that we may have any information from or about children under the age of 13 (16 in
Europe), please contact us at our contact information provided in Section 11.
5.3 Please note that all persons under the age of majority are required in their respective
jurisdictions to have a parent or guardian read and accept this Privacy Policy and the
Terms of Service on their behalf. Parents are encouraged to supervise their children’s
use of our Services and to become familiar with the types of content available through
our Services. Parents should oversee their children’s use of e-mail, forum and other
online communications.
6. Security of User Information
We follow generally accepted industry standards and maintain reasonable safeguards to
attempt to ensure the security, integrity, and privacy of the information in our
possession. As further security measures, we implement the following technical and
managerial safeguards to ensure that any personal information of users we handle is
secure from loss, leaks, or damage:
A. Improving Network Security - We implement various technical measures to prevent
the leakage of your personal information by unauthorized access to its network via
hacking, computer viruses, etc., and continuously monitors network access.
In addition, to ensure the security of communications between its server and database,
we use strong encrypted communication methods.
B. Conduct Security Training and Designation of Privacy Officer - We conduct regular
security training for our employees on the protection of your personal
information. Furthermore, we have designated a privacy officer to develop expertise in
the handling of your personal information and to minimize the risk of information
leakage.
C. Restrict Access and Storage - The location in which the handling and storage of
personal information are performed has been designated as a secure area and access
thereto has been restricted to personnel with the requisite authority. Documentation,
storage mediums, and electronic records containing personal information are stored in a
location equipped with a locking device or on a computer with restricted access.
D. The use and holding period of personal information - The company shall continue
to hold the personal information provided by the user while the user maintains the
qualificaion, and shall destroy the collected personal information directly after the
purpose of collection and use of the personal information is achieved.
In case of withdrawal of consent for the provision of personal information, the collected
personal information shall be destroyed immediately and shall not be used for any
purpose.
7. Management of Personal Information and Your Choice
7.1 We make good faith efforts to give you a right to access your personal information
to have errors in your personal information rectified, to object to the processing of your
personal information on legitimate grounds, data portability, etc. You and your legal
representatives may review and change your personal information through the user
information review/change function provided by our Services or through written request
to a customer service representative. However, in cases where your personal information
is connected to a third party platform such as SNS, chatting service, etc., any requests for
review and changes to personal information must be made in accordance with the
procedures provided by such third party platform operator.
7.2 To exercise any of your other rights under applicable law, you may contact us using
our contact information in Section 11. Upon verification of your identity, we respond to
your request within a reasonable period of time, and in accordance with relevant
laws. If, however, permitted under applicable laws, we may not be able to respond to
your request when any of the following applies:
A. Disclosure is likely to harm the life, body, property, or other rights or interests of yours
or another individual;
B. Disclosure is likely to seriously impede the proper execution our business;
C. Disclosure violates other laws; or
D. When you failed to verify your identity upon your disclosure request.
7.3 In the event that you request us to correct certain inaccuracies regarding your
personal information, we will take necessary measures to rectify the situation, including
correcting the inaccuracies without delay or providing an explanation to you as to why
the inaccuracies remain unchanged. Any personal information that is subject of the
foregoing request will not be used or provided to a third party until after we have taken
the aforementioned necessary measures. Notwithstanding the foregoing, we may still
use, or provide the personal information a third party, when it receives a request for
personal information pursuant to applicable laws or regulations.
7.4 You have the right to object to our processing of your personal information. You
may object to the processing of your information in the following circumstances:
A. Personal information is processed for directing marketing purpose (includes profiling);
B. Processing is necessary for the purpose of the legitimate interests pursued by the
controller;
C. Processing is necessary for the performance of a task carried out in the public interest
or in the exercise of official authority vested in the controller; and
D. Personal information is processed for scientific or historical research purpose
7.5 Any collected personal information will be retained and used as long as your user
status with our Services is maintained; for the length of time needed to fulfill any of the
applicable purposes of use described in this Privacy Policy; or to comply with laws and
regulations. We may retain your personal information following the closure or
termination of your user account if retention is reasonably necessary to comply with
applicable laws, regulations or legal obligations; to provide and complete customer
support service; to resolve disputes between or with other users, for the duration of the
applicable limitation period; or to detect and deter unauthorized or fraudulent use of, or
abuse of Services.
A. Right to Erasure - You have the right to request us to destroy personal information
without undue delay. You may exercise this right by contacting us using our contact
information in Section 11.
B. Destruction Process - We will destroy personal information when 1) requested by you
and/or 2) that is past its retention period using the methods that prevent recovery of
such information.
C. Destruction Methods – 1) Personal information saved in a digital format is
permanently deleted by using a technology that prevents recovery of record and 2)
Personal information printed on paper is destroyed by shredding or incinerating the
document.
8. California Privacy Rights
This Section shall apply to California residents only. Under the California Consumer
Privacy Act (the “CCPA”), California consumers have the right to request that we disclose
what personal information we collect from you, to delete the information, to opt-out of
the sale of your personal information, and the right not to be discriminated against for
exercising one of your California privacy rights. We do not sell your personal information
and do not discriminate you in response to privacy rights request.
A. Right to Opt-Out – We use and share your personal information only in accordance
with this privacy policy. We do not believe this use and sharing is a sale under the CCPA.
We have not sold your personal information in the last 12 months and we currently do
not have any plans to sell your personal information in the future.
B. Shine the Light Law – We do not share your personal information with third parties for
the purpose of direct marketing.
C. Do Not Track – California law requires us to inform you how we respond to web
browser Do Not Track signals. Because there is no industry or legal standard for
recognizing or honoring Do Not Track signals, we do not respond to Do Not Track
signals at this time.
D. Exercising your rights – If you want to exercise your privacy rights or if you have any
questions regarding our practices, please e-mail us at zeus69@panggame.com
9. Legal Matters
9.1 If any court or other competent authority finds any of the terms of this Privacy Policy
to be invalid or unenforceable, the remaining terms of this Privacy Policy will not be
affected and will be given full force and effect.
9.2 This Privacy Policy is governed by, and interpreted in accordance with, the laws of
the Republic of Korea. Any disputes arising in connection with this Privacy Policy will be
subject to the exclusive jurisdiction of the courts of the Republic of Korea.
9.3 We are constantly innovating and looking for new ways to improve our Services and
websites. We may therefore modify this Privacy Policy from time to time to reflect such
improvements or any other changes to our business. We strive to inform you about any
significant changes to this Privacy Policy that may be viewed as possibly disadvantageous
to you in any material way. If you object to any of these changes, please stop using the
Services immediately and close any account you may have with us.
10. Changes to Privacy Policy
The Privacy Policy may be updated from time to time to reflect any changes to relevant
laws and regulations or to our internal policy. We will provide notice regarding any
changes to the Privacy Policy before such changes are scheduled to take effect by 1)
disclosing the changes on our website; and/or 2) any other conspicuous means within
the Services that allow you to learn about the changes.
11. Contact Us
For questions and information about Privacy Policy and your rights, please contact us at
zeus69@panggame.com, or alternatively by writing to:
PangSky Corporation
Attn: Chief Information Security Officer
25, Nonhyeon-ro 80-gil, Gangnam-gu, Seoul, Republic of Korea
