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.
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