Privacy Policy

This Privacy Policy (“Policy”) explains how Action Square CO., LTD Services (from now on, “Action Square,” “we,” “us,” or the company”) collects, stores utilize, or otherwise processes personal data of end-users of our Services as defined below (referred to as “you” or “your” in this Policy), and what rights you have if we are processing your personal data.

In this Policy, “Services” refers to our Games, Websites, and any related services or properties we directly control. “Games” refers to online games or applications that we own and operate.

We use the term “your data” or “personal data” to refer to data that relates to you as an identified or identifiable individual (such as your name or email address), including non-personal data that can be combined with other data to identify you potentially. You must read and accept this Policy before accessing or using our Services so that you are aware of how and why we may use data relating to you. In addition to this Policy, we encourage you to carefully review our Terms of Service, which govern your use of our Services.



CONTACT INFORMATION

In matters related to this Policy, you can reach us by email at sb_help@action2quare.com. You can also contact us by mail at Action Square Co., LTD., 20F, 419, Teheran-ro, Gangnam-gu, Seoul, Republic of Korea.

WHY DO WE PROCESS YOUR DATA, AND ON WHAT BASIS?

2.1. LEGAL BASIS

When we process or collect your data, we ensure that we have a legal basis for doing so. Below, you can find examples of the different purposes for which we process your data and the legal basis we have for each of those reasons:

To perform our contract with you (e.g., the license we grant to you to use our Services by the Terms of Service), we may process your data as necessary to:

Based on our legitimate interest in constantly improving our Services, we may process your data to:

Based on our legitimate interest to make sure our Services are a fair and safe environment for all users and to maintain security for our Services and business, we may process your data to:

With your consent, we may process your data to:

Finally, we may process your data as necessary to:

In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above.

2.2. ADVERTISING

Advertising is one of the tools that helps fund our Services and enables us to make our Games available free of charge. We may show our ads and ads from third parties in our game. We also advertise our Games outside of our Services on third-party properties such as websites or applications

When you see ads in our Games, we may share your Advertising ID and IP address with our advertising partners if you have given your consent to use your data for personalized ads. Our advertising partners may also collect non-personal information directly from our Games through technologies such as software development kits (SDKs). In each case, they may use such data for several purposes, including limiting the number of times you see an ad or personalizing the ads you see to make them more relevant to you (for example, based on the past activity they have associated with your Advertising ID). For more information, please refer to the privacy policies of our advertising partners below;

Google https://policies.google.com/privacy
Facebook https://www.facebook.com/privacy/explanation
Apple Search Ads http://www.apple.com/privacy
UnityAds https://unity3d.com/legal/privacy-policy
IronSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Vungle https://vungle.com/privacy
AdColony https://www.adcolony.com/privacy-policy

When you see our ads outside of our Services (for example, on third-party properties such as websites or applications), the ad network involved in delivering that ad to you may, based on information such as the past activity they have associated with your Advertising ID, have determined that you may be interested in our Services. When ad networks use your Advertising ID in these ways, they do so based on their respective privacy policies or notices.

Ad networks may also use your data to:

For both ads in our Games and our ads outside of our Services, Advertising IDs or other identifiers are also used for ad measurement, which involves the collection of metrics such as total views, clicks, or installs generated by an ad. Measurement data may be directly or indirectly collected or received by multiple parties involved in ad delivery (including our advertising partners and us) through technologies such as web beacons inserted into ads. This data is used to provide measurement services, detect, investigate, and prevent fraud or fraudulent behavior, or settle payments between the parties involved in ad delivery.

WHAT DATA DO WE PROCESS?

We may process the following data relating to you:

We do not expect or intend to collect or otherwise process any special categories of data relating to you. By particular types of data, we mean genetic, biometric, or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offenses or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.

WHERE DO WE COLLECT YOUR DATA FROM?

We may collect data relating to you from the following sources:

Providing data to us is not mandatory. However, we cannot offer the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this Policy, depending on the Services you decide to use and your choices when using them.

WHO DO WE SHARE YOUR DATA WITH?

We may share your data with third parties to achieve the purposes described in this Policy. This may include sharing data with the following types of recipients:

In addition, please consider that some information you submit or make available through the Services may be visible to other users of our Services. This typically applies to, for example, your public profile information in our Games (such as your in-game alias), your chat messages in our Games, and data used to provide social features such as clans or leaderboards. We encourage you to carefully consider what information you wish to share in this manner.

HOW LONG DO WE KEEP YOUR DATA?

We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including to provide you with the Services or to comply with any legal, accounting, or reporting requirements. We may periodically delete or de-identify inactive accounts or other data in our Games or other Services. After the applicable retention period necessary for the safe performance of Services, we will either delete or de-identify your data or, if neither deletion nor de-identification is possible (for example, due to information being stored on a backup server), isolate your data from further processing until deletion or de-identification is possible. We may continue to use data that is not identifiable to you (for example, aggregate data).

HOW DO WE KEEP YOUR DATA SECURE?

We have adopted measures to provide your data with a level of security appropriate for the degree of risk involved with the data processing activities described in this Policy. These measures protect your data against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. The specific criteria we employ vary depending on the sensitivity of the data but typically include, for example, encryption, pseudonymization of identifying data where feasible, physical and technological controls to limit access to services or systems that contain personal data, and maintaining procedures to handle any suspected security incidents.

YOUR RIGHTS

With respect to our processing of your data, you may:

You may also withdraw your consent for processing your data at any time. Please be aware that we may continue processing your data despite your withdrawal of support if we also have another lawful basis. To access your data in our Games or to request its deletion, please get in touch with us at sb_help@action2quare.com.

To exercise your rights, you may also contact us at sb_help@action2quare.com. When you submit a request to exercise your rights, we must verify that you are the consumer to whose personal information the request relates, or a person authorized to act on that consumer’s behalf. We may ask you to provide further details on the account to which the request relates, enabling us to confirm that you are the account holder or acting on their behalf upon the request.

While we will usually not do so, we reserve the right to charge you an appropriate fee for exercising your requests permitted by applicable laws and regulations. If you believe that we have infringed your privacy rights, please get in touch with us at sb_help@action2quare.com so we can try to resolve the issue. If you are an EU resident, you have the right to complain to your local supervisory authority.

INTERNATIONAL TRANSFER

Action Square is a company based in the Republic of Korea, and to provide you the Services, your data will be transferred to the Republic of Korea for processing and stored on Microsoft Azure. Using Action Square’s Services, you acknowledge and consent to process your data in the Republic of Korea.

Since the Republic of Korea is considered a country that does not ensure “an adequate level of protection,” according to the art. 45 of the General Data Protection Regulation (“GDPR”), Action Square relies on specific appropriate safeguards and derogations for safe transfer provided in the art. 46 and 49 of the GDPR. Namely, Action Square collects and transfers your data to the Republic of Korea only due to the following circumstances: 1) because we entered into a contract with the Microsoft Azure or another service provider incorporating standard data protection clauses; 2) to perform a contract (providing you with the Services under our Terms of Service); 3) your consent.

NOTE FOR CALIFORNIA RESIDENTS

If you are a California resident, please be aware that under the California Consumer Privacy Act of 2018, as amended (“CCPA”), you are entitled to specific rights regarding your data. Besides other rights outlined in this Policy, California residents have the following rights:

– The right to opt-out of the sale of your personal information. We do not sell your personal information in exchange for money. However, we may disclose a limited amount of your personal information (i) to our advertising partners to enable them to deliver an ad that is relevant to you or (ii) to our marketing or licensing partners to enable them to send you relevant offers when you have opted into such communication.
This includes the following categories of your personal information:

Because this disclosure of information could be deemed a “sale” in the meaning of the CCPA, we ask for your explicit consent to disclose your personal information to our advertising or marketing partners for the above purposes. You can contact us at sb_help@action2quare.com to exercise your right to opt out

– Non-Discrimination. You have the right not to be discriminated against for exercising your rights under the CCPA.

AGE LIMIT

By accepting our Terms of Service and using our Services, you represent at least 13 years of age. Therefore, if you are under 13 years of age, please do not provide your data to us or use the Services to make your data available to others. If we discover that we unintentionally hold personal data relating to a user under 13 years of age, we will promptly delete the data from our records. If you have reason to believe we hold personal data relating to a user under 13 years of age, please contact us.

CHANGES

We may update this Policy from time to time due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. We may also inform you of any changes by other means appropriate to the significance of the changes.