Privacy Notice

This privacy notice is a summary of our Privacy Policy. These summaries are intended solely to simplify things and the full contents should be read as they take priority in the event of any ambiguity or conflicts. So be sure to read the whole privacy policy carefully.

The Data Controller for Personal Information

The Data Controller for the personal information is KRAFTON, Inc.

KRAFTON, Inc. will collect, store, use, and share the data to provide Services. We will act in a legitimate interest to legally process the data for managing the data subject and fulfill the contractual requirement.

The Collection and Use of Personal Information

We collect your information in two ways:

1) Information collected directly from you (e.g. nickname, email address)

2) Information collected automatically (e.g. device info such as device ID, browsing info, language setting, and/or service usage history such as IP address, etc.)

The Purposes of The Processing for Personal Information

We use your information to operate our Services and to improve the quality of the Services. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations, and given our legitimate interest in being able to provide and improve the functionalities of Services.

Sales and Sharing of Personal Information

We share your information to provide you with the best service environment, for example, with cloud service providers. However, we do not sell personal information to third parties and do not share personal information with third parties for cross-context behavioral advertising.

Data Protection and Transfer to Third Countries

We have put in place appropriate security measures, including encryption and de-identification to protect your information. When we transfer your information to countries and other regions outside of your location, we will take reasonable steps to safeguard the privacy of your information.

Contact Details

If you have any questions about this notice or our Privacy Policy, please contact us at your convenience. We endeavored to fully answer your request in good faith.

The contact details of KRAFTON are:

- Contact Information: privacy@krafton.com

- Address: 231, Teheran-ro, Gangnam-gu, Seoul, Republic of Korea 06142

Privacy Policy

Effective Date: 2024.08.07.

1. Introduction

KRAFTON Inc. (“we”, “our”, “Company” or “us”) collects, uses, and processes information about you (“you”, “user”, “Author”, “Contributor”, “Creator” or “player”). We provide various services related to inZOI (i.e. game, Canvas, event, survey, or customer service) ("Service(s)"). This Privacy Policy (“Policy”) covers the personal information that is provided, collected, or generated when you access, use, or subscribe to our Services, except where separate privacy policies or terms and conditions apply. This Policy applies to our Services, and also explains the rights and choices you have with respect to this data, and how you can communicate with us. This Policy does not apply to and cannot control activities when you click or visit other sites from our Game and Services.

We will occasionally update the Policy. When we do, we will revise the effective date above. While we will periodically inform you of this Policy or any material changes to it, your continued use of our Services after such changes means you accept the Policy as revised. We encourage you to periodically review this Policy to stay informed about how we collect and process your personal information. From time to time, we may ask you to confirm your acceptance of this Policy when we offer our Services.

2. What Information Do We Collect

We will collect the following categories of information that may directly or indirectly identify or describe you or your device or information that may be reasonably capable of being associated with or reasonably linked to you or your device. The information you provide to us may differ depending on the circumstances. For example, these include:

1) Identifiers such as SteamID64, email address, password, date of birth, nickname, name, IP address, postal address, phone number, date of birth, country of residence, language, nationality, etc.;

2) Internet or other electronic network activity information, such as browsing behavior and device information while using our Services (i.e. OS version, device ID, time zone settings, browsing info, etc.), etc.;

3) Crash report and system activity details; and

4) Purchase information, such as purchase date, items, etc.

When you participate in social features (such as Canvas), the information that you disclose such as creative works info(i.g. title, content(description), hashtag, etc.) and relationships and interactions with other players (including those not connected to you, and/or unspecified users outside Services through internet searching) such as following lists, comments, and likes, is public information. We may store and access it, and it may be read, copied, collected, or used by other users without your consent.

We use this data to operate and improve our Services. Some of this information is collected through our use of cookies and related online tools/technologies. See our “5. Cookies and Related Technologies” section below for more information.

We may ask for your consent to use your information for specific reasons. Where consent was provided and is required, you may withdraw your consent at any time by contacting us at the address provided in this Policy.

3. How We Use Your Information

We use the collected information for a variety of purposes, primarily, to provide the Services to players like you and to improve the quality of our Services. These include:

1) To operate and provide our Services;

2) To develop new services, improve the quality of our Services, and fix bugs;

3) To detect and act upon the illegal or unauthorized use of our Services;

4) To manage inquiries and requests from you;

5) To provide advertising information and other information on marketing and promotional events and surveys;

6) To track usage patterns, analyze trends of users, and calculate statistics on Services;

7) To prepare user statistics and provide Service metrics (such as a ranking on Canvas);

8) To participate in partnership programs;

9) To prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, cheating, hacking or criminal activity; and

10) To comply with and enforce legal requirements, agreements, and policies.

Most of the time, our processing of your personal information is necessary to respond to you or process your request. We may also process your information to comply with a relevant legal obligation. From time to time, we may ask for your consent to use your information for specific reasons. Where consent was provided and is required, you may withdraw your consent at any time by contacting us at the address provided in this Policy.

4. How We Share Your Information

We share certain personal information with third parties to provide our Services to you, including service providers that process personal information on behalf of us to provide our Services to you, like customer support and to manage our community. Some examples of these third parties are provided below. However, we do not share your information with third parties for cross-context behavioral advertising.

1) cloud computing service providers to provide cloud storage services; and

2) Payment service providers to assist with payment for transactions or provide withdrawing service for sellers;

3) marketing platforms and providers of analytics services relating to player behavior, to tailor the Service and conduct marketing activities;

4) Online survey service providers to improve the Services; and

5) Customer service providers to manage users’ inquiries;

We may share your information where such disclosure is essential to comply with a legal obligation or a lawful data access request, pursuant to a merger or acquisition, with our affiliates(LIST: https://krafton.com/en/studios/) for the purposes described in this Policy, or where you have otherwise provided your consent or at your direction.

5. Cookies and Related Technologies

We use cookies, and other technologies to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes. Approved third parties may also set cookies and related technologies when you use our Services. We or third parties may use cookies and similar technologies, or collect data about your machine or device, for fraud prevention, security, and authentication purposes. For more details on this, please refer to our Cookie Policy.

6. International Data Transfers

We operate globally and to provide our Services may transfer your data to countries and other regions outside of the country where you are located. If your personal information is transferred, stored, or processed by us, we take reasonable steps to safeguard the privacy of your personal information, including entering confidentiality and standard contractual clauses with vendors where appropriate. Additional information concerning the international transfer of your information is available depending on your region. See the supplemental terms section below for more information.

7. Retaining and Deleting Personal Information

In principle, we will remove your personal information without delay after the purpose of collecting personal information is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using technical measures in a way that the information cannot be reproduced. However, we may retain your personal information even after you have closed your account with us or we have ceased providing Services to you, if retention of your personal information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Policy or any other agreement we may have with a player.

8. Our Policy Concerning Children

When we process the user’s information under the age of digital consent, we will obtain consent from parents or guardians to collect personal information from their children before they are using our Services. If you are a parent or guardian and you believe your child has provided us with information without this process, you can contact us and request your child’s information to be deleted from our system.

9. Links and Third-Party Services

If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave our website and go to the website you selected. Because we cannot control the activities of third parties, we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website linked to our Services, you should consult that site’s privacy policy before providing any personal information.

10. Security of Your Information

We have implemented appropriate security measures, including encryption and de-identification, to protect your personal information. In addition, we limit access to your personal information to those employees, agents, persons, or companies who have a business need to know or access the information. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality where appropriate. Please note, however, that no data transmission over the internet is 100% secure, and that complete security of any information we collect and use therefore cannot be guaranteed. Our information protection activities are annually audited by external authorities consistent with the Korean information security standard ISMS-P (Personal Information & Information Security Management System).

11. Your Privacy Rights

Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, and erasure of your own personal information. To make a request concerning your rights or if you have any other questions, please contact us by sending an email to the address specified in the “12. Contact Us” section. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

The result of handling privacy rights requests submitted by player globally during 2023 are as follows:

1) Rights to access

- Requests received: 19

- Requests completed in Whole or in Part: 19

- Requests Denied: 0

- Average days to complete: 4.6 days

2) Rights to deletion

- Requests Received: 245

- Requests Completed in Whole or in Part: 245

- Requests Denied: 0

- Average days to complete: 7.5 days

3) Rights to opt-out of Selling

- Requests Received: 1

- Requests Completed in Whole or in Part: 1

- Requests Denied: 0

- Average days to complete: 4 days

12. Amendments

We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Services. If we make material changes, we will post a prominent notice on our websites or in our Services or give you other reasonable notice before any material changes take effect. All other changes are effective upon posting.

13. Contact Us

If you have any questions about this Policy, or your dealings with our Services, please contact us by sending an email to privacy@krafton.com.

This Privacy Policy has been translated into other languages for your convenience. In case of any discrepancies between the English version and the other versions, the English version shall prevail. However, Korean Privacy Policy shall prevail for users based in Korea.

Appendix. SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC

This portion of our Policy applies to residents of the jurisdictions indicated below. In the event of a conflict between the Policy and this section, this section supersedes and controls.

1. EEA and UK

If you are in the European Economic Area (EEA) or the UK, you may lodge a complaint with an applicable data protection authority for your country or region where an alleged infringement of applicable data protection law occurs.

Our representative in the EU is VeraSafe Netherlands BV, located at Keizersgracht 555, 1017 DR Amsterdam, Netherlands. To contact them, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.

Our representative in the UK is VeraSafe United Kingdom Ltd., located at 37 Albert Embankment, London SE1 7TL, United Kingdom. To contact them, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.

1) International Data Transfer

If we transfer your data outside of the EEA to a country that is not recognized by the European Commission as ensuring an adequate level of data protection, we endeavor to apply suitable measures to safeguard your personal data under applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the latest standard contractual clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for personal data). You may ask for a copy of such appropriate measures by contacting us as set out in this Policy. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.

2) Your Privacy Rights

You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with may be that of your habitual residence, where you work, or where we are established.

2. United States

1) Privacy Rights for United States Users

Several U.S. states provide their residents with rights to:

a. Confirm whether we process their personal information;

b. Access and delete certain personal information;

c. Take their data from one location to another (data portability);

d. Opt-out of personal data processing for targeted advertising and sales;

e. Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose; and

f. Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights submit a request form in our support page (URL: https://support.playinzoi.com/). To appeal a decision regarding a consumer rights request, follow the instructions in the written notice we will provide to you.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: (e-mail: privacy@krafton.com, Support center: https://support.pubg.com/). However, please know we do not currently sell data triggering that statute’s opt-out requirements.

2) California

If you are a California resident, you may have additional rights as detailed below. Within the preceding 12 months, we have collected or disclosed the following categories of personal information about you:

a. Identifiers such as SteamID64, email address, password, date of birth, nickname, name, IP address, postal address, phone number, date of birth, country of residence, language, nationality, etc.

- How collected: When you access or play our Services, we collect this directly from you.

- How disclosed: With our affiliates and service providers (e.g., platform service provider, cloud storage service provider, payment service provider, marketing platform service provider, online survey service provider, customer service provider, and deliver service providers)

b. Characteristics of protected classifications such as date of birth, language, nationality, etc.

- How collected: When you access or play our Services, we collect this directly from you.

- How disclosed: With our affiliates and service providers (e.g., platform service provider, cloud storage service provider, online survey service provider, customer service provider).

c. Internet or other electronic network activity information, such as browsing behavior and device information while using our Services (i.e. OS version, device ID, time zone settings, browsing info, etc.), etc.

- How collected: When you access or play our Services, we collect this automatically.

- How disclosed: With our affiliates and service providers (e.g., platform service provider, cloud storage service provider, marketing platform service provider, customer service provider).

d. Geolocation information obtained by IP address.

- How collected: When you access or play our Services, we collect this automatically.

- How disclosed: With our affiliates and service providers (e.g. platform service provider, cloud storage service provider, payment service provider, marketing platform service provider, customer service provider,).

e. Commercial information, such as purchase date, items, etc.

- How collected: When you purchase items in Services, we should be automatically collected from third party’s

- How disclosed: With our affiliates and service providers (e.g., platform provider, cloud storage service provider, payment service provider, customer service provider).

f. Audio, electronic, visual, thermal, olfactory, or similar information such as profile image (when you set the profile on Canvas), etc.

- How collected: When you access or play our Services, we collect this automatically.

- How disclosed: With our affiliates and service providers (e.g., platform service provider, cloud storage service provider, customer service provider)

We determine the retention period for each of the categories of personal information listed above based on our business or commercial purposes for obtaining the information, our legal or regulatory requirements applicable to such information, and in relation to litigation or to protect our rights.

- Your California Privacy Rights

You may exercise the following rights at any point in time in connection with your personal information. To exercise such rights, please email us at privacy@krafton.com or visit our support page to request your rights.

Please note that at least your email address will be required to submit a request, and additional information may be required so we can verify you. If you exercise your rights via email, you must specify the right(s) you wish to exercise.

We will verify your identity and respond to your request within 45 calendar days. If necessary, we may take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, in which case we will notify you to explain the reason for the delay.

a. Right to Know & Right to Access

You have the right to request the following information from us up to two times within a 12-month period:

- the categories of personal information that we have collected from you over the past 12 months, and the specific pieces of personal information we have collected from you;

- the categories of sources from which personal information was collected;

- the business or commercial purposes for which personal information is collected;

- the categories of personal information that we have disclosed for a business purpose or sold during the past 12 months; and

- the categories of third parties to whom the information was disclosed or sold (if applicable).

b. Right to Delete

You have the right to request that the personal information collected from you be deleted.

c. Right to Correct

You have the right to correct your personal information. You can edit your personal information via email to privacy@krafton.com.

d. Right to Non-Discrimination

You have the right not to be discriminated against for exercising these privacy rights.

e. Right to opt-out of Selling and Sharing

You have the right to opt-out of the selling and sharing of your personal information as defined by California law by requesting that your personal information not be sold or shared in any form. With respect to targeted advertising, you can control the sharing of your personal information for targeted advertising purposes through our website by opting out from advertising cookies through the cookie banner.

HOWEVER, WE HAVE NOT “SOLD” PERSONAL INFORMATION TO THIRD PARTIES AS THAT TERMS IS DEFINED BY THE CCPA WITHIN THE PAST 12 MONTHS. ALSO, WE HAVE NOT “SHARED” PERSONAL INFORMATION WITH THIRD PARTIES FOR THE PURPOSE OF CROSS-CONTEXT BEHAVIORAL ADVERTISING.

f. Rights for California Minors

Minors under the age of 16 have the right to request the deletion, correction, or copies of information publicly posted by you, such as on forums or bulletin boards.

g. Shine the Light

You have the right to request the categories of the personal information that we disclosed to third parties for their direct marketing purposes during the past 12 months and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for their direct marketing purposes.

h. Limit Use and/or Disclosure of Sensitive Personal Information

You have the right to limit our use of your sensitive personal information. However, WE DO NOT USE YOUR SENSITIVE PERSONAL INFORMATION for purposes that require us to offer this limitation option. If we collect your sensitive personal information, we will get your consent.

- Authorized Agent

You may designate another person or entity (“authorized agent”) to act on your behalf in connection with your request for rights that are guaranteed by the CCPA. An authorized agent is a natural person or business entity registered with the Secretary of State to conduct business in California that you have authorized to act of your behalf to make a request to know or to delete.

To use an authorized agent for your request, we require that you provide signed permission to your agent. Your authorized agent can submit a request to know or delete by sending an email to privacy@krafton.com. If you contact us, we can offer you an authorized form for your agent to submit.

The above requirement does not apply should your agent have power of attorney pursuant to Probate Code sections 4000 to 4465. Please note that we may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Under the CCPA, your agent is responsible for implementing and maintaining reasonable security procedures and practices to protect your information and use your personal information only for the purpose of fulfilling your request.

If you have any questions about this Policy, or about exercising your rights described above, you can contact us by email at privacy@krafton.com.