Privacy Policy
Effective Date: June 15, 2022
1. Identification of Data Controller.
For the purposes of this
privacy policy (¡°Privacy Policy¡±),
the ¡°Data Controller¡± is GameSpring CO., LTD.
registered at 23, Gangnam-daero
84-gil, Gangnam-gu, Seoul, Republic
of Korea. Subsequently, ¡°We¡±, ¡°Us¡± and ¡°Our¡± refer to the Data Controller.
This Privacy Policy applies
to usage of any of Our games, apps, products, services content, including but
not limited to http://www.gamespring.co.kr/, http://www.dragonacecasino.com/, and/or other domains or
websites operated by Us, hereafter referred to as our ¡°Services¡±.
GameSpring respects your privacy and is
committed to making Our practices regarding your data more transparent and
fair. This Privacy Policy describes how We collect, store, use, and disclose
your personal information (hereafter also referred to as ¡°personal data¡±) when
providing Our Services to you. Furthermore, this Privacy Policy also describes
your rights and choices concerning your personal information.
If you do not want GameSpring to collect, store, use, or share information in
the ways described in this Privacy Policy, you are prohibited from using any of
Our Services.
2. The Information We Collect, How We Collect It, and the Legal
Basis of it.
We need to collect and use
certain data to provide the Services to you. While using Our Services, you may
provide Us some of your personal information. We will store your information in
Our systems for the exclusive purpose described in this Privacy Policy.
The legal basis for
collecting and using the information depends on what the information is and the
context in which We collect it.
Generally, We will normally
process your personal information for a legitimate interest in efficiently
fulfilling Our contractual and legal obligations, account management,
management reporting, market review and analysis, promotion of Our Services,
and business development. In some cases, the processing is necessary to perform
Our contract with you (i.e., Our Terms of Service) or to fulfill legal
obligations, or to protect your vital interests or those of another person (for
example, another user).
Information You Provide To Us.
When you use Our Services,
you may be asked to provide Us some or all of the following personal
information:
Additional information may be
requested for the purposes of securing your account and/or improving Our
services.
Furthermore, We may also
collect the following non-personal information:
We may also allow you to
create a public profile, which other users of Our Services may be able to see.
Your public profile may include the following information:
Information You Generate Using Our Services.
Additionally, when you use
Our Services, We may collect information about the ways in which you use and
interact with Our Services, such as when and for how long you play Our games,
game features, and other players you interact with, purchase you make, progress
or levels you achieve, and other gameplay activities.
Customer Support.
If you contact Our Customer
Support team, We may collect and store the contact information you provide
(this may include, but is not limited to, your name and your email address,
information about your gameplay or activity on Our Services, your game ID,
username, operating system, and Unique Device Identifier (UDID)). We may also
store the communications you have with Our Customer Support team and any
additional information in those communications in order to provide ongoing
support and improve Our Services.
Use of Social Media.
If you access any of Our
Services through Social Media (for example, Facebook or Twitter), We may
receive certain information about you. The information We receive is determined
by each particular platform and the consent that you have provided to them.
Please note, third party
social networks are governed by their own privacy policies, terms, and end-user
agreements, and We are not responsible for and have no control over the sharing
practices or policies of the third parties that operate those sites. For
additional information, contact Us at support@gamespring.co.kr.
It is your responsibility to
review and understand the third-party¡¯s terms of services and their privacy
policy.
Payment Information.
When you use any of Our
Services that are connected to a third-party application or platform, for
example, Apple, Google, or Amazon, any monetary transaction ¡°a purchase¡± that
you make will be processed by that third-party provider. You may be subject to
that third party¡¯s terms of service and/or that third-party¡¯s privacy policy.
We do not receive any of your
financial information. However, We may receive non-financial information
related to your transactions within Our Services, for example, your name, your
approximate physical location, and the item or service that you purchased.
The information that We
receive is dependent on which Service you are using and which third-party
provider manages the transaction.
Our Terms of Service explain
Our policies regarding charges, billing, third-party credit, and virtual currencies.
For more information, refer to our Terms of Service.
Cookies and Other Automated Information Collection.
As described in Our Cookie Policy, We use cookies to recognize
you and/or your device(s) on, off, and across different Services and devices.
We may also allow our third-party service providers to use cookies and similar
technologies in accordance with Our Cookie Policy. You may control or opt-out
of the use of cookies and similar technologies by following the steps described
in Our Cookie Policy.
3. How We Use Your Information.
We will use the information
that you provide to Us for the specific purposes for which you provided that
information, as stated at the time of collection. Hereunder are some of the
ways in which We may use your information:
4. How We Share Your Information.
We will not share the
personal information We collect from you through Our Services with third
parties, except as described in this Privacy Policy. We may share your
information with third parties or allow third parties to collect this
information from Our Services in the following circumstances:
To Other Users.
As mentioned above, your
public profile (such as profile photo, nickname, country, and game statistics)
will be able to be seen by other users of Our Services.
To Third-Party Advertising, Including Behavioral Advertising
and Analytics.
We may share some of your
data, such as your advertising ID, with advertisers for the purpose of
tailoring the advertisement you see when you use Our Services. We use
advertising to be able to offer some of Our Services for free.
These advertisements may
include, without limitation, video ads, banner ads, and ¡°offerwalls¡±
in which third-party advertisers may provide virtual currency or other in-game
items to users in exchange for completing a task.
The offers displayed within
Our Services are created and hosted by third-party providers, not by GameSpring.
To enable advertisers, ad
networks, and offer wall providers to serve you with more relevant ads, they
may collect, or We may collect and share with them, the following types of
information when you use Our Services:
In addition to serving you
with relevant ads, the information collected may be used to:
Ad networks may collect this
data through the use of cookies and other similar tracking technologies, and
they may use a single tracking technology or multiple tracking technologies at
the same time.
After clicking on a
third-party advertisement or offer, you may no longer be on a
website/application/service hosted by Us. We are not responsible for the
privacy practices or the content of those third-party services.
Activities related to
third-party advertisements within Our Services are subject to the terms of
those third-party companies¡¯ privacy policies. We cannot guarantee that other
third-party companies¡¯ privacy policies will have the same terms and conditions
as Our Privacy Policy. In the use of third-party provided services, such as
in-game advertising and purchasing, it is your responsibility to review and
understand all relevant policies. You may review applicable third party privacy
policies here.
To Third-Party Service Providers.
GameSpring uses third-party companies
to perform its services, like processing payments, analyzing data, optimizing
gameplay, email delivery, hosting services, managing, and delivering contextual
and tailored advertisements. We may share your information with third-party
companies who perform services on Our behalf, like analytics, analysis, hosting
services, customer service, marketing, and advertising optimization. We may
also share your data with our third-party partners who assist us in delivering
and optimizing our Services, such as our platform partners (Apple, Google,
Facebook, etc.). Where We share your data with third-party service providers
and partners, We make every effort to ensure that there are appropriate agreements
in place to protect your information.
About our Third-Party Data Controllers and Processors.
GameSpring¡¯s Partner List includes a list
of trusted third parties companies with which We work directly or indirectly,
and which may receive your personal data and further process that data
according to their policies. We encourage you to review our partners' privacy
policies to ensure that you understand their treatment of personal data that
they may process.
From time to time, We may add
new partners to this list or remove partners with which We no longer share
information. Please be aware that when We share your data with third-party
service providers and partners, We do so in adherence to our policy of making
every effort to ensure that there are appropriate agreements in place to
protect your information.
List of third party
data controllers and processors.*
*Please note that We may not
share your data with all of Our partners.
How Can You Turn Off Personalized Ads?
You are always free to
opt-out from the future collection of your information by GameSpring
in accordance with this Privacy Policy by choosing not to use Our Services.
In addition, you can take the
following steps to control the collection of your information:
iOS
If you are using an iOS device, you can find the official guide for opting out
from Apple here.
Android
Open the ¡°Settings¡± application
of your Android device and select the ¡°Google¡± menu item. Depending on your
device, this option may not be visible on the main menu, but you may use the
search function at the top of the Settings menu to find it. From there, select
the ¡°Ads¡± sub-item and activate the option ¡°Opt out of Ads Personalization¡± to
prevent the creation of profiles and the display of personalized advertising.
You can delete the advertising ID on the same menu at any time (¡°Reset
advertising ID¡±), and then a new ID will be created and will not be merged with
the previously collected data.
Please note that if you reset
your advertising ID or opt-out of interest-based advertising, you may still see
advertisements in Our Services, but those ads will not be targeted based on the
identifiers mentioned above. For example, such ads may be instead based on
contexts, such as your progress and actions in Our Services, or your language
preferences. Please be aware that such actions may result in a less enjoyable
user experience.
5. How Long Do We Store Your Personal Information.
The period for which We will
retain your personal information is dependent on the reason for which it has
been collected. We will never retain your personal information for longer than
is required to provide you with Our Services or to meet our legal obligations
or to exercise, defend and protect Our rights, whichever is longest.
The personal information that
associates you with an account and/or any of Our Services will be retained for
at least as long as you have an active account with Us.
In the event you ask Us to
delete or close your account, We will take all reasonable measures to delete
your personal information from Our records. However, in the case that you have
opted and agreed to submit optional content to Our Services, We may be unable
to remove that content in its entirety. Additionally, We may retain select
information where We need and have the right to do so, such as for legal and/or
accounting purposes. Such cases may include but are not limited to, information
related to your payments or customer service inquiries. We may also keep
information in order to exercise, defend, or establish Our rights.
For more information on
deleting or closing your account, please refer to article ¡°9. Your Rights¡±.
6. Security Measures for Your Information.
We implement all recommended
industry practices in security measures to protect your personal information.
We take all reasonable actions to prevent any unauthorized access or use of
your personal information.
However, please be aware that
regardless of any security measure used, We cannot and do not guarantee that
hacking, data loss, unauthorized access, or any other type of breach will never
occur. Any transmission of information is done at your own risk.
7. International Data Transfers.
GameSpring operates globally, and Our
Services are global by nature. Your personal information collected via and/or
by Us may be stored anywhere in the world and may be transferred to, and
processed in, countries other than the country of which you are a resident.
These countries may have data protection laws that are different from the laws
of your country.
When We transfer your
personal information internationally, We take steps to ensure that adequate
safeguards are in place to protect your personal information, and it is treated
securely, lawfully, and in accordance with this Privacy Policy.
8. Policy Regarding Children.
The safety and privacy of
children are of paramount importance to Us. Our Services are not intended for
nor directed at users under the age of 17 (the ¡°Children¡±). We will never
knowingly collect or solicit information from any Children. Children are
prohibited from using any of Our Services.
Parents or guardians that
believe that We do hold information about their Children should contact Us at privacy@gamespring.co.kr.
9. Your Rights.
Your rights include, but are
not limited to:
To exercise any of your
rights, please submit a request to privacy@gamespring.co.kr. You may be required to
provide particular forms of proof of identity in order that We do not disclose
personal data to those that are not entitled to it.
When you request the
elimination of your personal information, We will only retain information that
is subject to the terms described in Section ¡°5. How Long Do We Store Your
Personal Information.¡±
10. Changes to the Privacy Policy.
From time to time, it may be
necessary for Us to amend Our Privacy Policy. We will post any changes to Our
websites, and We will update the date at the top of the Privacy Policy.
The amended Privacy Policy
will be effective upon posting on any of Our Services.
We highly recommend you to
visit Our websites often to review Our Privacy Policy.
If you continue to use Our
Services following an amendment to Our Privacy Policy, that usage constitutes
an agreement to and acceptance of the terms of that revised Privacy Policy.
11. Compliance with the General Data Protection Regulation
(GDPR).
If you are a user using Our
Services in the European Union or the European Economic Area, please read
carefully the terms and conditions in this Section.
We strive for strict
compliance with the applicable terms and conditions in the European Union¡¯s
General Data Protection Regulation (hereinafter ¡°GDPR¡±).
Our definition of Personal
Data (hereafter the ¡°Personal Data¡±) found in this section is in concordance to
the definition contained in Article 4 of the GDPR. We will process your
Personal Data in accordance with the applicable terms of the GDPR.
We will collect your Personal
Data only with the purpose of providing Our Services, as described in Section
¡°3. How We Use Your Information,¡± Section ¡°4. How We Share Your Information,¡±
and in this Privacy Policy. Once achieving the purpose of the collection of the
Personal Data, We will use all reasonable effort to immediately and promptly
delete all your Personal Data.
As set out in the GDPR, the
requests you can make to Us can include:
Upon your request, We will
promptly respond to your inquiry to the best of Our ability in accordance with
the applicable provisions in the GDPR.
For more information about
the personal data We process, or if you wish to exercise any of your rights,
please send Us a request by email at privacy@gamespring.co.kr.
12. Notice to California Residents.
This part of the Privacy
Policy addresses the specific disclosure requirements under the California
Consumer Privacy Act of 2018 (Cal. Civ. ¡×¡× 1798.100–1798.199) and the
California Consumer Privacy Act Regulations by the Attorney General
(collectively, ¡°CCPA¡°). Strictly for the purpose of this part of the Privacy
Policy, the term "Personal Information" shall be as defined in the
CCPA. This Notice to California
Residents only applies to individual residents of the State of California in
the United States of America.
Collection and Use of Personal Information
When We use the term
"personal information" in this Notice, We mean information that
identifies, relates to, describes, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular
consumer.
In
the last 12 months, We may have collected the following about consumers for the
following purposes.
Category of Personal Data Collected |
Personal Data Collected (Examples) |
Source of Personal Information |
Categories of service providers to whom Personal
Data was disclosed |
Business Purpose for Collection |
Identifiers |
Name, username, email address, social media identifier, IP address,
advertising ID, device and operating system information. |
-
Our players. -
Our player¡¯s devices. -
Social networks. -
Third parties. |
-
Customer services vendors. -
Advertising networks. -
Social media services. -
Data analytics vendors. -
Quality assurance vendors. -
Cloud storage providers. -
Service providers. -
App distribution platforms. |
- Operate Our business and provide Our
Services. - Product development/improvement. - Customer service. - Detecting/Protecting against security
events. - Internal analytics and reporting. - Internal research. - Game mechanics or functionality. - Facilitate player¡¯s social interaction. - Maintaining and enhancing service,
debugging. - Advertising and direct marketing. - Detecting/Protecting against security
events, preventing fraud and abuse of Our policies. - User acquisition. - Compliance purpose and meeting
legal/regulatory requirements. |
Personal
Data Categories listed in the California Customer Records Statute (Cal. Civ.
Code ¡× 1798.80(e)) |
Name. |
|||
Commercial
Information |
Transaction
information, purchase history. This does not include any payment information,
which is collected directly by the mobile app distribution platform. |
|||
Protected
classification characteristics |
Age,
gender. |
|||
Internet
or other electronic network activity information |
Interaction
with Our Services. |
|||
Geolocation Data |
Location. |
|||
Inferences
drawn from the above. |
N/A. |
We allow certain third-party
advertising partners to collect the categories of personal information
identified above (please see the table), for online advertising purposes.
These ad networks, social
media companies, and other third-party businesses may collect personal
information directly from a browser or device through cookies or similar
tracking technologies. When a consumer visits or interacts with Our Services,
these third parties may collect personal information and use your personal
information to:
These third parties may use
this personal information for their own commercial purposes in accordance with
their own privacy policies, which may include providing this information to
additional third-parties, including other advertising networks.
Please see Our Cookie Policy for more information about
how third-parties use cookies and related technologies to automatically collect
information on Our Services and the rights you may have in relation to those
practices.
Please review Our partners' privacy policies to ensure that you understand
their treatment of your personal data that they may process.
List
of third party data controllers and processors.*
*Please note that We may not share your data with all of Our partners.
Selling Personal Information
WE DO NOT "SELL" PERSONAL DATA OF OUR USERS AS MOST
PEOPLE WOULD TYPICALLY UNDERSTAND THAT TERM. However, as mentioned previously, We do allow certain third-party advertising partners to
collect information about consumers through Our games for purposes of serving
ads that are more relevant, for ad campaign measurement and analytics, and for
ad fraud detection and reporting. In order to serve you personalized ads, We may share your resettable identifiers provided by your
mobile device¡¯s operating system with Our selected partners. Typical
advertising IDs are ADID (Android) and IDFA (Apple). These mobile advertising
IDs allow developers and marketers to track activity for advertising purposes
and enhance the personalization of ads. You may reset these identifiers from
within your mobile device or limit ad tracking for your mobile device, as
mentioned in this Privacy Policy.
Your California Privacy Rights
Your rights include, but are
not limited to:
Right
to know |
You
have the right to request any or all of the following information relating to
the personal information We have collected about you or disclosed in the last
12 months, upon verification of your identity: -
The specific pieces of personal information We have collected about you. -
The categories of personal information We have collected from you. -
The categories of sources from which the personal information is collected. -
Our business or commercial purpose for collecting personal information. -
The categories of third parties with whom We share personal information, if
any. |
Right
to deletion |
You
have the right to request the deletion of personal information that We have
collected from you, subject to certain exceptions. |
Right
to Non-Discrimination |
You
have the right not to receive a discriminatory treatment for exercising any
of the rights described above. However,
please note that if the exercise of the rights described above limits Our
ability to process personal information (such as in the case of a deletion
request), We might no longer be able to provide you Our Services or engage
with you in the same manner. |
Right to designate an authorized agent to
submit CCPA requests on your behalf |
You
may designate an authorized agent to make a request under the CCPA on your
behalf. To do so, you need to provide the authorized agent written
permission, and the agent will need to submit to Us proof that they have been
authorized by you. |
The Right to Opt-Out of Personal Information
Sales |
You have the
right to direct Us not to ¡°sell¡± personal information We have collected about
you to third parties. |
How to Exercise Your California Privacy Rights
To exercise any of your
rights, please submit a request by:
You may be required to
provide particular forms of proof of identity in order that We
do not disclose personal data to those that are not entitled to it.
To exercise your deletion
rights, please refer to article ¡°9. Your Rights¡± of this Privacy Policy and
follow the instructions provided.
Note that GameSpring does not currently
respond to Do Not Track signals, whether that signal is received on a computer
or on a mobile device.
13. Contact Us.
If you have any comments,
questions or concerns regarding your privacy or this Privacy Policy, please
send us a message at privacy@gamespring.co.kr.
For all other matters, please
contact GameSpring through support@gamespring.co.kr or by physical mail to
GAMESPRING CO., LTD., 23, Gangnam-daero 84-gil, Gangnam-gu, Seoul, Republic of Korea.