1.  INTRODUCTION

KRAFTON, Inc. and/or its affiliates (“we”, “our”, “Company” or “us”) collect and process information about you (“you”, “user”, or “player”). We provide video game (“Game(s)”), official sites (“Site(s)”) and services related to the Game (i.e. event, survey, Esports, or customer service) (“Service(s)”) to players. This Privacy Policy (“Policy”) describes how we collect, use, and share personal information about you during and after relationship with us in accordance with applicable data protection laws.

It is important that you read this Policy, together with any other notice we will provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such personal information and what are your rights.

2.  INFORMATION WE COLLECT

We collect information about you when you play our games and use our services. This Information may be required to enter into a contractual relationship with you or to perform a contract with you (such as to provide Service at your request), and failure to provide any information may result in our inability to provide requested game or services. The information we collect falls into two different categories:

1) Information collected directly from you

You may provide us with the following information when playing our Game and/or using our Services. The information you provide to us may differ depending on the circumstances. For example, these include:

– gamertag(*), purchase history, etc. to provide and operate the Game;

– Nickname, email address, device information, purchase history, and records of the issues you experience (to provide customer service), and

– Email address, gender, age, country of residence, language, and information for delivering goods (i.e. name, postal address, and phone number)(for participation in the survey, and other events).

When you participate in social features (such as in-game chat), the information that you disclose 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 collect certain information from your third party platform’s profile/account as permitted by the terms of the third party platform and your privacy settings thereon.

2) Information collected automatically

We automatically collect certain information when you play our Games and/or use our Services. The type of information that we automatically collect may vary, but generally includes:

– Device information (including but not limited to, IP address, device ID, device model, network type, OS version, time zone settings, battery status, screen resolution, etc.),

– Device event information, including crash reports and system activity details (e.g. whether you encountered an error using our services or lost internet access, etc.), and

– Your browsing behavior while using our Site and/or Services.

3.  COOKIE 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 site or games.

1) Cookies

Cookies are small files downloaded to your computer (if your browser is enabled to accept cookies) to track movements within websites and to customize your experience within the website. Most Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of the Site may not function properly.

We do not control cookies in third party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. The ads appearing on the Site may be delivered to you by third-party advertising companies. These companies may use information about your visits to this and other websites in order to provide advertisements on the Site and other sites about goods and services that may be of interest to you.

2) Website Analysis

We use analysis services on this Site to allow us to record information on the use of this Site and to constantly improve our offering.

This Site uses Google® Analytics, a web analysis services offered by Google Inc. (“Google”). We may use the following advertising functions of Google® Analytics and collect personal information as provided by Google, and you may withdraw your consent by deactivating such functions in Google’s advertising settings: Remarketing by using Google® Analytics; Google® Display Network Exposure Report; Google® Analytics Demographics and Interests Report; and Integrated service allowing the collection of data through Google® Analytics by using advertising cookies and anonymous IDs.

More information about Google’s own privacy policy can be found at https://www.google.com/policies/privacy.

If you wish to opt-out from your information or data being used by Google Analytics, you may download the Google Analytics Opt-out Browser Add-on available here: https://tools.google.com/dlpage/gaoptout

Sizmek collects anonymous information from players visiting the Sites utilized allow Sizmek to collect this information entirely anonymously and allow us to deliver interest-based advertising. More information about Sizmek’s privacy policy and how to opt out can be found at https://www.sizmek.com/privacy-policy/

3) Anti-Cheat and Fraud Prevention Technology

We strive to provide a safe and fair gaming environment for all players. When you play the Game, 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. We also may use other anti-cheat technology with our services.

4.  HOW WE USE YOUR INFORMATION

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

– Operating and providing the games and services,

– Providing opportunities to participate on the events, or surveys that relating to the game(e.g. to deliver goods to players),

– Providing customer service by collecting and responding to inquires,

– Sending you newsletters about our game,

– Providing advertising information and other information on marketing and promotional events and survey (e.g. offering personalized in-game contents),

– Solving technical problems and improving the quality of the game (for example, to provide realistic gaming environment to users),

– Identification of individual players to provide the game,

– Technical protection against usage of unauthorized programs,

– Preventing inappropriate gameplay that could harm other players, and

– Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity.

In the majority of cases, 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 certain specific reasons. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal by contacting us at the address provided in this Policy.

5.  SHARING YOUR INFORMATION

We give permission to third parties including service providers which process personal information to provide customer support and to manage our communities. Examples of these third parties include:

– third party program restriction providers to block cheating tools and unauthorized programs,

– anti-cheating detection providers, fraud prevention vendors to provide a safe and fair gaming environment,

– cloud computing service providers to provide cloud storage services,

– payment service providers to assist with payment for transactions or providing withdrawing service for sellers,

– marketing platforms and providers of analytics services relating to player behavior, in order to tailor the Service and to conduct marketing activities,

– online survey service providers in order to improve the game service,

– customer service providers to answer users’ inquiries, and

– real-time voice transmission platform providers to provide voice chat services.

We may also 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 for the purposes described in this Policy, or where you have otherwise provided your consent or at your direction.

6.  INTERNATIONAL DATA TRANSFERS

We operate globally and to provide our Services may transfer your data to countries and other regions outside of where you are located. If your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. For certain countries we process the data in certain regions (as set out in more detail below).

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

We do not knowingly collect, use or share any personal information about children (age rating depends on the country where you reside) without verifiable parental consent or as permitted by law. Some of the features on our Games and Services are age-gated so that they are not available for use by children. If you are a parent or guardian and you believe your child has provided us with personal information, 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 the Site and go to the site you selected. Because we cannot control the activities of third parties, we do not have responsibility for any use of your personal information by such third parties, and 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 that is linked to our Games or Services, you should consult that site’s privacy policy before providing any personal information.

10.  SECURITY OF YOUR INFORMATION

We have put in place appropriate security measures, including encryption and de-identification, to prevent your personal information from being accidentally leaked, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, etc. who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have put in place safety procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. However, we will not be responsible for any problems that may arise of despite those safety measures and procedures, such as your negligence or problems on the internet. Please note 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.

11.  OTHER AGREEMENTS THAT GOVERN YOUR USE OF THE SITE

In addition to this Privacy Policy, your rights and obligations concerning the use of the Site are governed by our Terms of Service, any other supplemental agreements, and other applicable policies, guidelines, and requirements. When you sign up to use the Site, please review each of the aforementioned agreements carefully, as you must agree to be bound by each of the agreements before you may use the Service.

12.  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, erasure, and portability of your own personal information. To make a request concerning your rights or if you have any other question, please contact us by sending an email to the address specified in the “14. 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.

13.  AMENDMENTS

We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Site. You will be deemed to have accepted such amendments by continuing to use the Service, so please review it frequently.

14.  CONTACT US

If you have any questions about this Policy or your dealings with this Site, please contact us by sending an email at pubg_privacy@pubg.com.

This Privacy Policy has been translated into other languages for the convenience of the players. 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 Korean players.

[SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC]

In the event of a conflict between the supplemental Terms – Jurisdiction Specific that are relevant to your jurisdiction from which you are playing our Games or using our Services, and the rest of the Policy, the relevant jurisdiction’s Supplemental Terms – Jurisdiction Specific will supersede and control.

1.  EEA, SWITZERLAND AND UK

If you are an EEA, Switzerland, or a UK residents, you may have additional rights.

1. A) 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 in accordance with 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.

1. B) 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 notably may be that of your habitual residence, where you work or where we are established.

1. C) Representative in the EU

The GDPR(for EU Residents) requires a written designation of a representative in the EU by the controller or processor not based in the EU. Contact information and address of VeraSafe in the EU are as follows. Also to make such an inquiry about personal data processing, please contact VeraSafe.

– Name of our Representatives: VeraSafe

– Address: Keizersgracht 391 A, 1016 EJ Amsterdam

2.  UNITED STATES
3. A) NEVADA

If you are a Nevada resident, we do not sell your personal information that we collected, Nonetheless, if you are Nevada residents who purchased our game items or goods from us, you may submit a request to record your preference to opt out for the future.

1. B) CALIFORNIA

If you are a California resident, you may have additional rights. You can check the rights in below.

– PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice (“Notice”) for California residents provided pursuant to the California Consumer Privacy Act (“CCPA”) supplements the Privacy Policy of KRAFTON, Inc. and its affiliates (“we”, or “us”) and provides additional information on how your personal information is collected, used, disclosed and processed online or offline. Unless otherwise specified, all terms used within this Notice shall carry the same meaning as they are defined in our Privacy Policy(“Policy”). This Notice and the Policy together constitutes our “California Privacy Policy”.

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 (“personal information”). We have collected these same categories of personal information from consumers over the past 12 months. Please refer to our Policy concerning the categories of sources from which this personal information is collected.

Also, we may provide service providers or third parties with certain personal information to provide or improve our services. Within the past 12 months, we disclosed or shared each of the following categories of personal information with the following categories of third parties. We do not ‘sold’ personal information to third parties as that term is defined by the CCPA.

– Categories of personal information

1) Identifiers

– Categories: IP address, email address, gamertag, contact information(such as postal address, phone numbers)

– Categories of Third-Parties to whom personal information was disclosed: payment service providers, online survey service providers, customer service providers, program restriction providers, cloud computing service providers, delivery service providers2) Internet or other similar network activity information

– Categories: website, application or advertisement browsing history, device model, OS version, device storage, and information about the device that you are playing

– Categories of Third-Parties to whom personal information was disclosed: program: payment service providers, online survey service providers, customer service providers, program restriction providers, cloud computing service providers

– 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 pubg_privacy@pubg.com.

Please note that at least your email address will be required to submit a request. 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 can take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, provided that we notifies you to explain the reason for the delay.

1) Right to Access

You have the right to request the following information up to two times within a 12-month period. Categories of the personal information that was disclosed for a business purpose or sold during the past 12 months, and categories of third parties to whom the information was disclosed or sold.

– 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

– Categories of the sources from which personal information was collected

– Business or commercial purposes for which personal information is collected

2) Right to Request Deletion

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

3) Right to Opt-Out of Personal Information Sales

You have the right to “opt out” by requesting that your personal information not be sold in any form. However, we do not sell personal information.

4) Right to Non-Discrimination

You have the right to not be discriminated against for exercising your privacy rights under the CCPA.

5) Rights for California Minors

Minors under the age of 18 have the right to request the deletion of and/or obtain information posted on websites such as forums or bulletin boards.

6) Shine the Light

You have the right to request the categories of the personal information that we disclosed to third parties in the last year for direct marketing purposes and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for direct marketing purposes.

– 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.

In order 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 pubg_privacy@pubg.com. If you contact us for the request we will offer you an authorized forms to support.

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.