Shadow Arena Privacy Policy

1. What type of information does Pearl Abyss collect?

 

2. Why does Pearl Abyss collect personal information?

 

3. Who does Pearl Abyss share your personal information with?

 

4. How long does Pearl Abyss retain personal information?

 

5. How does Pearl Abyss transfer personal information overseas?

 

6. How does Pearl Abyss protect your information?

 

7. What are Cookies? How does Pearl Abyss use Cookies?

 

8. What rights and choices do I have pertaining to my personal information?

 

9. Children

 

10. How do you contact us?

 

Pearl Abyss (Pearl Abyss Corp., Pearl Abyss Pearl Abyss Taiwan Corp., Pearl Abyss H.K. Limited., and Pearl Abyss America, Inc. hereinafter referred to as "Pearl Abyss", "Company", “us” or “we”) provides PC, Console, Mobile, and game/other related services (hereinafter referred to as “services”). Pearl Abyss may store, proces, and share personal information in certain circumstances in order to provide testers with its services. Pearl Abyss recognizes the importance of protecting the personal information of testers, and does its utmost in protecting the personal information provided by testers using our services. 

 

This Privacy Policy is intended to inform you of how we use the personal information provided to us and how we work to protect personal information.


The Company may periodically change the Privacy Policy due to changes in government laws and guidelines or changes in our internal policies. In the event the Company revises/amends the Privacy Policy, an announcement/notification will be provided through the official website. Please refer to the official website in order to view the changes.   

 

This Privacy Policy applies to all services we provide.

 

  1. 1. What type of information does Pearl Abyss collect?

The Company collects the following personal information for Beta registration/access, customer support, and event entry, 

 

1) Information provided to us by testers

 

① Information provided to us during Beta registration on the official website

- (Within the Republic of Korea) Email address, date of birth, mobile number, country information

- (Within other regions) Email address, date of birth, country information 

 

※ The Company does not collect personal information from children under the age of 15 (Republic of Korea), 18 (Brazil/South Africa), 16 (other regions) .

 

②  Information collected from Beta participation through a Steam ID: member identification information


※ Information other than member identification information will not be collected/stored when participating in the Beta through a Steam ID. 

 

③ Additional information provided to us
- Additional information may be collected from testers of the service, such as the usage of each service within the website, event participation, and registering for prizes.   

- In the event additional personal information is collected, the Company will inform these testers and receive their agreement regarding「Types of Personal Information Collected」,「Purpose of Collected Personal Information」, and 「Retention/Storage of Personal Information」.

Service Name

Required/Optional

Collected Personal Information

Customer Support

Required

Email Address

Optional

Name, Mobile Number, Date of Birth, Address, Automatically Generated Information, Device Identification Information, Other Information Necessary for Customer Support

※ Depending on the nature of the inquiry, the collected personal information may differ or there may be additional personal information collected. 

Register for Events/Promotions 

Optional

Name, Mobile Number, Address, Gender, Date of Birth, Email Address

※ Depending on the event and/or promotion, the collected personal information may differ or there may be additional personal information collected. 

Prize Delivery

((Within Republic of Korea))

Required

Prize Requiring Physical Delivery: Name, Address, Mobile Number 

Prizes via Mobile (Coupons): Mobile Number

Public Charges and Taxes
(Within Republic of Korea)

Required

Resident Registration Number, Name, Address

 

2) Data generated while using our services

 

The following information may be collected during the Beta. 


- Data related to the progress of the game

- Chat records, login IP information, PC information (e.g., CPU type, RAM size, graphic card type, etc.)    

- Data involving service use, such as gameplay data and interactions with other players within in the service 

- Error information, MAC information  

- Screenshots of the game window (recorded in the event of a game client error) 

- Data collected through Cookies and other similar programs/techniques 

- Web browser information, general location data

- Advertising ID

 

Additionally, Pearl Abyss collects the following information concerning testers when using our services from our third-party partners.

 

- Data for advertising and analysis (e.g. Google Analytics)

 

 However, you can block Google Analytics from collecting data about you.

  Block Google Analytics: https://tools.google.com/dlpage/gaoptout/

※ Weblog tools must be blocked individually for each tool.


2. Why does Pearl Abyss collect personal information?

The Company collects and uses personal information from testers for the following reasons

1) Process the necessary data to provide services.

The Company processes information necessary to provide services to testers due to our contractual relationship with them. 

 

- To operate our services

- To allow testers to register for the Beta and access it

- To provide products and services requested by testers

- To provide service information requested by testers

 

2) Collect data to provide more customized/appropriate services to testers.

The Company has a legitimate interest in collecting and processing the necessary data to accomplish the following objectives in order to provide users more customized/suitable services.   

 

- To improve and develop the services provided by the Company

- To improve and develop game service optimizations and gameplay experiences

- To manage information configured by testers

- To provide software updates

- To maintain the personal settings of testers and deliver content

- To provide support for testers’ feedback and inquiries

- To send notices/announcements such as changes to the Terms of Service, service issues, updates, security alerts, and other support messages 

- To organize an event or promotional program

- To send event/promotional prizes.

 

3) Processes data necessary to maintain safe and fair services.

The Company has a legitimate interest in collecting and processing the data necessary to accomplish the following objectives in order to maintain safe and fair services. Please see our Terms of Service for legal usage policies.

 

- To prevent fraudulent and unauthorized access 

- To provide services for protecting personal information of testers

- To ensure gameplay across multiple devices 

- To allow appropriate chat either automatically or manually 

- To find bugs, errors, and solve issues

- To adhere, investigate, and restrict legal disputes, fraud, and other illegal behaviors

 

4) Processes data necessary for personalized advertising.

The Company has a legitimate interest in collecting and processing the data related to the use of the Company services, other websites, and email for personalized advertising. However, profitable advertising will only be sent (direct marketing information) if you have agreed to receive marketing information:

 

- To track your online behavior while using the Company services and other related information;

- To personalize advertising and deliver targeted marketing and promotional offers to you;

- To present suggestions and information regarding services you may like.

 

5) For all the above cases and purposes, we reserve the right to analyze and classify any collected data.

The Company has a legitimate interest in collecting and processing the data we need to fulfill our contracts, provide and maintain appropriate services, and organize customized advertising.

 

  1. 3. Who does Pearl Abyss share your personal information with?

The Company does not share information that can personally identify testers to third-party companies without consent. Nevertheless, the Company shares information to third parties if it is required by law or is deemed necessary to enforce our rights, property, operations; or to protect users or third parties; or if we engage partners and service providers in order to provide our services to testers.

 

1) Tester has agreed beforehand 

Prior to collection and provision of the personal information, the Tester shall be informed of “who will be provided with their personal information; what will be provided; and why it be provided”. The personal information will not be provided to third parties without the Tester’s agreement. 

 

2) Partners and third-party service providers

- The Company provides the information to its vendors, consultants, marketing partners, research firms and other service providers or business partners. In this case, the contents will be disclosed through this Privacy Policy.

 

The Company may send personal information to the following third-party service providers for the following purposes.

 

Partners

Purpose

Location

Metanet Mplatform

(Within Republic of Korea) Send notices, customer support services, processing information to delivery of prizes to customers

Republic of Korea

11Street Co.,Ltd.

(Within Republic of Korea) Delivery of gifticons

Republic of Korea

SUREM Co.,Ltd.

(Within Republic of Korea) Provide and manage the messaging system

Republic of Korea

Innova Co. SARL (Innova)

(Within Russia) Provide customer support, handle complaints and civil affairs, send notices, process inquiries

Russia

Elite Global

(Within North America, Europe) Provide customer support, handle complaints and civil affairs, send notices, process inquiries 

Philippines



3) Public authorities

- The Company may share your information to third parties and public authorities to comply with the law and to curb fraud and illegal behavior.

- The Company may share your information to third parties and public authorities to protect the safety and property of the Company, employees of the Company, and you.

 

4) Advertising companies and social media

- The Company may share your information to advertising companies and social media (Facebook, Google, Twitter). Relevant third parties will have access to your information in accordance with the Privacy Policy to use tools that interact with social media, in-game advertising, and other operations of third-party companies. For more detail on how these third-party companies handle your information, please refer to the relevant third-party partner’s Privacy Policy.

 

5) Delivery companies

- The Company may share your address and contact information you provided to delivery companies to ship prizes. The information we provide the delivery Company with will only be used for delivery purposes.


4. How long does Pearl Abyss retain personal information?

The Company retains and uses collected personal information (with tester’s consent) for up to 1 year. In principle, the Company will destroy the personal information without delay when the purpose of collecting and using the personal information is accomplished (when requesting cancelation of Beta registration, when the event you participated in ends, etc.).

 

Procedure and method of deleting personal information are as follows. 

 

① Deletion procedure

Personal information shall be deleted within 1 year after the end of the Beta. However, personal information may be retained due to the relevant laws and data protection reasons until deleted according to the determined period of time (refer to「Collected Personal Information Retention and Usage Period」).

 

② Deletion method

Personal information printed on paper (printed, written, etc.) shall be destroyed by shredder or incineration. Personal information stored electronically shall be permanently deleted in a way that prevents recovery.

 

However, in accordance with the data-related laws of the Republic of Korea, the following information shall be retained for the period specified for each reason and shall not be used for any other purpose.

1) Information retention due to relevant laws   

 

① PROTECTION OF COMMUNICATIONS SECRETS ACT

- Login related records: 3 months

 

② ACT ON THE CONSUMER PROTECTION IN ELECTRONIC COMMERCE, ETC.

- Display/advertising related records: 6 months

- Contracts or application withdrawal related records: 5 years

- Payments and provision of goods related records: 5 years

- Customer complaints and disputes related records: 3 years

 

③ FRAMEWORK ACT ON NATIONAL TAXES, CORPORATE TAX ACT

- All transaction related ledgers and documents as regulated by tax laws: 5 years

 

2) Reasons for information retention due to other internal Company policies 

 

The Company may retain personal information collected for events/promotions for up to 1 year. However, the period may vary depending on each event/promotion, and the personal information collection and usage period disclosed on each event/promotion shall take precedence.

 

  1. 5. How does Pearl Abyss transfer information overseas?

Your information is sent overseas as the Company provides services worldwide. Each country may have different laws pertaining to information protection. These countries outside of the EEA (European Economic Area) may not have laws that are as comprehensive as your own country of residence. The Company will comply with the relevant laws to protect your information. Please refer to “6. How does Pearl Abyss protect your information?” for details on how your information will be protected. 

 

You may request to discontinue the transfer of your personal information at any time by contacting Service or by emailing to privacy@pearlabyss.com. However, if the personal information is not provided to foreign companies as requested, there may be restrictions on the use of the official websites and services.

 

In addition, when transferring your information to partners and service providers listed under “3. Who does Pearl Abyss share your information with?”, the Company transfers information in compliance with the European Commission’s Standard Contractual Clauses. Your information will be transferred with adequate protection. For more information, please feel free to contact the official website Support or privacy@pearlabyss.com.

 

  1. 6. How does Pearl Abyss protect your information?

The Company uses the following security/physical measures and management to prevent data loss, theft, breach, alteration, and destruction of personal information. However, the Company is not liable if the data is leaked due to tester’s negligence (e.g. losing Steam password), or mishaps outside of the Company’s control.

 

1) Security Measures

- The Company stores and encrypts personal information in accordance with the relevant laws and regulations.  

 

- Files and data transfers containing important information (including personal information) are protected by encryptions, file locks, or other such data security measures

 

- The Company continuously monitors the personal information of Testers from being leaked or destroyed by hacking or computer viruses. In addition, the Company utilizes Anti-Virus programs, Firewalls, and other various security devices to protect Tester’s information.

 

- The Company takes the necessary measures to safeguard database systems in order to process personal information.

 

2) Management

The Company manages the access to personal information to a minimum. The number of personnel given access to personal information is kept to a minimum and are as follows.  

 

- Personnel that are directly involved with marketing, events, customer support, and delivery (including personnel in partner companies and service providers)

- Personnel that are in charge of personal information including our Data Protection Officer

- Personnel that must have access to the information for other work-related tasks

 

The Company ensures regular training for personnel involved and entrusted with personal information security. 

The Company manages personal information-related tasks with the Privacy Policy established by the department in charge of protecting personal information. In addition, the Company strives to ensure internal rules are enforced and rectify issues as soon as they are discovered.

 

3) Physical Security

 

The Company has a separate location where personal information is physically stored. Entry and operation of this location is strictly monitored with an established entry protocol.

Documents with personal information and other forms of information storage are installed by locking devices in safe locations.

 

  1. 7. What are Cookies? How does Pearl Abyss use Cookies?

The Company uses ‘cookies’ to store and retrieve the information of testers. Cookies are a small text file sent to the tester's browser by the server used to run the website and are stored in the tester’s computer hard disk. The Company uses cookies for the following purposes. 


1) Purposes for using Cookies  

Analysis of Testers accessing the website and duration, to understand and track user preferences and interests, provide other personalized services by tracking the number of times the website has been accessed and other information.

 

The Company and third-party analysis service providers use tracking technologies such as cookies, beacons, tags, or scripts. These technologies are generally used by the Company to collect statistics about the websites to analyze tendencies, manage the website, and to understand how our website is used. The Company may receive collected data as a whole from analysis service providers that use these technologies.

 

2) How to block Cookies from being saved

 

Testers have the right to choose whether or not to install cookies. This can be done by going to the web browser’s option settings to allow all cookies, ask for permission each time cookies get saved, or to reject all cookies from being saved. However, blocking cookies may result in difficulties when receiving certain services.

 

① How to prevent cookies from being installed. 

- Internet Explorer: [Tools] → [Internet Options] → [Personal Information] → [Advanced]

- Chrome: Go to [⋮] at the top of the browser → [Settings] → [Advanced] → [Privacy and security] → [Site Settings] to change your settings.

※ Other browsers may have a different method to change cookie settings. 

 

② How to block targeted advertising

 

Block or select personalized advertising through the tracking settings for advertising.
 

- Android: Click on privacy settings then select to block certain ads.

- iOS: Click on privacy setting then select limit ad tracking.

 

 3) The Company also works with many other analytics and ad publishing partners on mobile apps and websites. The Privacy Policy used by each of the partners are listed below.

 

- Facebook: https://www.facebook.com/about/privacy

- Google: https://policies.google.com/privacy

- Twitter: https://twitter.com/en/privacy

 

  1. 8. What rights and choices do I have pertaining to my personal information?

Testers can request to view their registered personal information at any time. If the tester does not agree to the processing of their personal information by the Company, the tester may request to withdraw their consent or cancel their Beta registration. However, in the event the personal information is deleted due to cancellation of the Beta registration, the tester’s information generated and collected during the Beta may be deleted as well. 

 

Testers can request to look up their personal information through Support on the official website and request the cancellation of their Beta registration. Otherwise, please contact the contacts listed in the 10. How do you contact us?」. 


In the event a tester requests an error correction of their personal information, the personal information will not be used or provided until the correction is completed. In addition, if the incorrect personal information was already provided to a third party, the corrected information will be sent to the third party without delay.  

 

The Company shall process personal information to prevent access or use when it has been canceled or deleted at the request of the tester as described in 「4. How long does Pearl Abyss retain personal information?」. 

 

You can exercise the aforementioned rights at any time through Support on our official website or by email to privacy@pearlabyss.com.

 

 8.1 European Economic Area (EEA) Residents: Your EEA Privacy Rights

 

Users accessing the services from the European Economic Area have the following additional rights relating to personal information, but their effectiveness and procedures may be determined in accordance with the laws and regulations of individual countries.

 

1) The right to request the Company to send personal information to another Company.

2) The right to contact the supervisory authority

 

You can exercise the aforementioned rights at any time through Support on our official website or by email to privacy@pearlabyss.com.

 

8.2 California Residents: Your California Privacy Rights

 

Under the California Consumer Privacy Act (CCPA), you have the right to request the following information from the Company if you are a resident of California.

 

1) A description of the categories of personal information disclosed to any third-party to whom the Company may have disclosed your personal information for that third-party's direct marketing purposes within the previous calendar year.

2) Information that identifies any such third-party(ies)

 

The Company does not purposely share or sell your personal information to unaffiliated third parties for direct marketing purposes without your consent.

 

If you have any additional questions or concerns, please contact us through Support on our official website or by email to privacy@pearlabyss.com.

 

  1. 9. Children

The Company does not purposely collect or request any personally identifiable information from children under the legal age of each country (hereinafter referred to as “child” or “children”) or send targeted advertisements and suggest offers. 

The Company restricts children from using our services. If personal information has been collected from a child, the data shall be deleted as soon as possible.

 

  1. 10. How do you contact us?

If you have any questions about personal information protection or have issues related to personal information, please send an inquiry through Support on our official website.

 

Additionally, you can send all complaints related to privacy to our Data Protection Officer and the department for handling personal information issues/inquiries directly through the contact information provided below. The Company will answer your inquiries as soon as possible and as thoroughly as possible.

Data Protection Officer

Department for Handling Personal Information Issues/Inquiries

Name: Jin-Young Heo

Title: CPO

Phone Number: 1661-8572

Email: privacy@pearlabyss.com

Department: Operations Center

Phone Number: 1661-8572

Email: privacy@pearlabyss.com

 

10.1 Contact Information for Privacy Officers and Representatives in Europe

 

If you live in Europe, you can also contact us using the contact information listed below.

 

In-charge of Personal Information Protection: Pearl Abyss Corp.

Address: Simin-daero 327 beon-gil Dongan-gu, Anyang-si, Gyeonggi-do,14055, Rep. of KOREA

Email: dpo@pearlabyss.com

 

Personal Information Protection Officer in Europe and Contact Information:

VeraSafe has been appointed as PEARL ABYSS H.K. LIMITED's representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. 

VeraSafe can be contacted in addition to dpo@pearlabyss.com, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative

 

Alternatively, VeraSafe can be contacted at:

 

VeraSafe Czech Republic s.r.o

Klimentská 46

Prague 1, 11002

Czech Republic

 

This Privacy Policy will not apply to personal information collected on third-party websites linked in services provided by the Company. Please refer to the privacy policies of these websites when visiting them. 

 

Addendum

This Privacy Policy will be effective as of February 11th, 2020.

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