EFFECTIVE DATE: 18th February 2024
Thank you for using our products and Services! This Privacy Policy is applicable to the services such as website, game, player community on mobile devices, tablets, personal computers and other devices and offline activities by HK KURO GAMES LIMITED (collectively, "KURO GAMES", "we" or "us") provided to you (collectively, the "Services"). Your participation in, access to or use of any of our Services indicates your (hereinafter, "you" or "user") permission to this Privacy Policy. This Privacy Policy explains what information we collect from users, how we use and store the information, under which circumstances we will disclose the information to the third parties, what rights you or your parents and guardians have over this information, and how we protect this information. Please read this Privacy Policy carefully before using our Service.
If you are a resident of the European Economic Area, the United Kingdom of Great Britain and Northern Ireland or any other jurisdiction where data protection laws apply, we are the controller of your personal data. This Privacy Policy is an integral part of the Term of Use for the Services we provide. This policy is applicable to all the Services directly referencing or linking to this Privacy Policy, but not applicable to the services under separate privacy policies that are not included in this Privacy Policy.
This section mainly introduces the contents and methods of the Personal Information we collect, and how we use your Personal Information.
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Personal Information Categories |
Method of Collection |
How We Use the Personal Information |
Legal Basis (Applicable to Specific Jurisdictions Only) |
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Personal account information, including account name, nickname and password |
Voluntarily provided by you. |
Register for the KURO GAMES account. Serves as the premise for obtaining our various Services (including game service, recharge transaction and customer service, etc.), and also the basis for reasonable commercial activities such as data analysis and user violation investigation. Generate a user ID to associate with your game data and personal information. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract, or necessary for the purpose of our legitimate commercial interest.
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Identity verification information, including email address and mobile phone number (in some regions only) |
Voluntarily provided by you. |
Register for the KURO GAMES account. Serves as the premise for obtaining our various Services (including game service, recharge transaction and customer service, etc.), and also the basis for reasonable commercial activities such as data analysis and user violation investigation. We may use this information to send you verification code, game notice information, prize-winning information and marketing information. You may opt-out following the instructions in the information. According to the legal requirements in some regions, we may have to use this information to verify if you are a minor and fulfill compliance obligations. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract, or necessary for the purpose of our legitimate commercial interest, or we fulfill the legal obligations as necessary, or upon your permission. |
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The account information of third-party platform, including the account, nickname and email address of third-party platform
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We will obtain the information from third-party platform upon your authorization. |
Register for the KURO GAMES account. Serves as the premise for obtaining our various Services (including game service, recharge transaction and customer service, etc.), and also the basis for reasonable commercial activities such as data analysis and user violation investigation. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract.
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Date of birth (in some regions only)
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Voluntarily provided by you.
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According to the requirements of the local laws, rules and regulations in force, we may need your date of birth to determine if you are a minor and fulfill legal obligations accordingly.
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We fulfill the legal obligations as necessary.
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Information of the legal guardian, including the name and contact information
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Voluntarily provided by you. |
If you are a minor, we may need to collect the identity information of your legal guardian so as to abide by relevant requirements for minor protection in your region. |
We fulfill the legal obligations as necessary. |
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Mailing address
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Voluntarily provided by you.
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Verify your location. Mail the product or prize to you. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract. |
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Survey information, which may include the range of your age, gender, nationality, game experience, information of device (including hardware information, system information, network information, etc.), occupation and contact information based on different contents of the survey |
Voluntarily provided by you. |
Recruit, screen and send the result to the beta-test player of the game. Conduct surveys for the purpose of improving the game. |
Upon your permission, or necessary for the purpose of our legitimate commercial interest. |
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Hardware information, including name, type, model, manufacturer and brand of the device, CPU information (including CPU architecture information), mainboard serial number, battery and charging status, sensor information (including acceleration sensor, gyroscope and magnetic field sensor, rotation vector sensor and light sensor) |
We collect the information. |
Identify your device and realize security guarantee function (such as determining the uniqueness of the device logged in and security check of a new device). Monitor advertisement placement and evaluate the effect. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract, or necessary for the purpose of our legitimate commercial interest. |
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System information, including system version, device landscape/portrait display information (for iOS only), ROM, device display resolution and size, language region (including country code), memory, storage size and remaining space (including remaining space capacity of internal and external SD cards) |
We collect the information. |
Identify your device and realize security guarantee function (such as determining the uniqueness of the device logged in and security check of a new device). Monitor advertisement placement and evaluate the effect. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract, or necessary for the purpose of our legitimate commercial interest. |
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Identifier, including IMEI, MEID, MAC address, OAID, UUID, IDFA, IDFV |
We collect the information. |
Identify your device and realize security guarantee function (such as determining the uniqueness of the device logged in and security check of a new device). Monitor advertisement placement and evaluate the effect. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract, or necessary for the purpose of our legitimate commercial interest. |
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Network information, including network type, network status, operator information, IP address, ICCID and WIFI information
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We collect the information.
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Confirm the type of network access and ensure that you successfully access to the game server. Determine the country or region you are in. Enable the function of automatically downloading game resources when WIFI is available. Determine your game and transaction security and prevent fraud. Improve your game experience (e.g., to remind you that you are participating in the game with mobile data). |
We abide by the contract signed with you and provide Services necessary for the performance of a contract, or necessary for the purpose of our legitimate commercial interest. |
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Launcher information, including game application ID, launcher ID, launcher version and game version |
We collect the information. |
Provide related services for the PC terminal to start the game.
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We abide by the contract signed with you and provide Services necessary for the performance of a contract. |
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Gamelogs information, including personal account information, login logs, search and inquiry contents, item logs, milestones of the game, progress and game crash record, behavior data, moving speed, attack index, chat logs, nickname logs, and personalized signature logs
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We collect the information.
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Provide to you the function of reading relevant historical records at the game terminal. Analyze game operation statistics and game security, and handle user complaints, so as to optimize your service experience. In some regions, we may use the information to fulfill the anti-addiction requirements. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract, or necessary for the purpose of our legitimate commercial interest; in some regions, we fulfill the legal obligations as necessary. |
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Game security information, including gamelogs information, hardware and operating system information, list of installed applications, running task information, progress and game crash record information |
We collect the information. |
Detect pirate game, scan plug-in and prevent cheating, so as to maintain fair play and tackle with the behavior targeted at interfering or damaging the normal operation of the Services.
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We abide by the contract signed with you and provide Services necessary for the performance of a contract, or necessary for the purpose of our legitimate commercial interest. |
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Information of violations, including nicknames, personalized signatures and chatting information that violate relevant regulations
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We collect the information. |
Screen out improper information containing pornographic, violent, political contents, abusing words or malicious advertisement, so as to maintain a wholesome game space and cyberspace. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract, or necessary for the purpose of our legitimate commercial interest. |
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Charging and consumption information, including game account information, order No., transaction amount, transaction time, transaction goods or service information, consignee information, user ID and order No. of the third-party payment channel and payment status information |
We collect the information. |
Deliver related products or Services to you and provide after-sales dispute resolution service. Ensure the security of your transactions and payment and identify fraud. Enable the function of reading consumption records on the game terminal. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract. |
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Chatting records (including texts), friend-related records (including relationship with and number of friends, friend adding or deleting, and black list) |
We collect the information. |
Screen out improper information containing pornographic, violent, political contents, abusing words or malicious advertisement, so as to maintain a wholesome game space and cyberspace. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract, or we fulfill the legal obligations as necessary, or necessary for the purpose of our legitimate commercial interest. |
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Customer service information, including your contact information, call logs and contact records with us and their specific contents
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We collect the information. |
Match and verify your user identity, clarify the issue and dispute, so as to deliver timely response and resolution to your request. |
We abide by the contract signed with you and provide Services necessary for the performance of a contract, or necessary for the purpose of our legitimate commercial interest. |
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Access to camera
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Voluntarily authorized by you. |
Enable photo taking and uploading function during your use of our products or Services. If camera access is denied, photo taking and uploading cannot function normally; however, it will not affect your use of other product functions. |
Upon your permission. |
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Authorization to read/write into storage space (album)
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Voluntarily authorized by you. |
Enable the function of uploading the pictures or files from your device, save the images or videos from the game to your device, or save the in-game pictures via the in-game photo taking function during your use of our products or Services. If authorization is denied, the uploading/downloading function of the pictures, files or videos, in-game photo taking function and normal storage of the in-game pictures will be affected, but the other functions of the product will not be affected. |
Upon your permission. |
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Network authorization
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Voluntarily authorized by you. |
Realize normal access and use of the Internet during your use of the product or Services. If authorization is denied, your networking function and other Services or functions based on networking function (such as game service and game update function) will be affected; however, other functions of the product will not be affected. |
Upon your permission. |
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Clipboard authorization
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Voluntarily authorized by you. |
Copy contents from outside the game and paste the contents to the game, or copy contents from the game and paste the contents to the game or outside the game. If authorization is denied, function of the clipboard will be affected; however, other functions of the product will not be affected. |
Upon your permission. |
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Device microphone authorization
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Voluntarily authorized by you. |
Realize video uploading within customer service function. If authorization is denied, function of the customer service will be affected; however, other functions of the product will not be affected. |
Upon your permission. |
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Notice authorization
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Voluntarily authorized by you. |
Push the related notice of the game to you, including downloading progress, in-game push notice of stamina and activities. If authorization is denied, normal function of the game push notification will be affected; however, other functions of the product will not be affected. |
Upon your permission. |
We will only disclose your Personal Information to a third party when necessary. Information we collect from you is commonly shared with a third party in the following ways:
（1）We share your information to service providers and business partners, so as to provide you Service or improve your experience: e.g., your information may be shared to a payment service provider to complete your transaction or a third-party service provider to streamline the way you log in. Unless otherwise stipulated in applicable laws, our service providers can only access your Personal Information for the purpose of providing specific services to us, and should not disclose or use your data for any other purpose.
（2）We share your information within our corporate organization. Part of the Services you access and use may be supported by certain entities within our corporate organization. We may share the information we collect with members, a parent company, subsidiaries or other corporate affiliates of our corporate group as required to provide critical functions, such as storage, delivery and security.
（3）We may share your information with our advertisement placement platforms or the platforms for analyzing the effect of advertisement placement. These platforms help promote our Services by placing advertisements on other platforms, and help evaluate the effectiveness of our advertisements and those of our partners.
（4）We may share your information with a third party related to our corporate transaction, such as a merge, sale of assets or stock, restructure, financing, change of control, acquisition of all or part of our business, or, in the event of unlikely situations permitted under the applicable laws, such as bankruptcy or other similar business arrangements, the information we collect may fall within transferred assets.
（5）We may disclose any information we collect in response to subpoenas, court orders or demands, legal processes, enforcement requests, legal claims or government inquiries, and protect and defend our rights, interests and security. We may also share any information we collect to fulfill requirements of any applicable laws, exercise or defend any legal claims, and comply with any applicable laws.
（6）Upon your permission, we may share your Personal Information with a third party.
We will retain your Personal Information for the period necessary for providing Services to you (or for any other purpose outlined in this Privacy Policy). In addition, on the premise that we own legitimate commercial interests (e.g., for the purpose of developing and improving the Services, enhancing the security and stability of the Services, etc.), or when we intend to comply with the contract or legal obligations, or exercise or defend our legal rights we will retain your Personal Information when necessary. Depending on the situation, such as the type of information and the purpose for which we use the information, the retention period will vary. For example, when we process your information in order to provide Services to you, we will retain the information as long as you keep an account with us. In certain circumstances, we may collect or anonymize your Personal Information as far as permitted by applicable laws, and use the information on the basis of pseudonymization and de-identification, for research or other purposes.
Based on the various service-providing contracts we sign with you, your Personal Information may be stored and processed by the server outside of the region of your residence. Our teams around the world (including the People’s Republic of China, the Hong Kong Special Administrative Region of the People’s Republic of China and the Republic of Singapore) can access your information from outside of the region of your residence. No matter where our servers are, we will take appropriate measures to defend your rights in accordance with this Privacy Policy. Our game servers are located in the United States of America, the Republic of Singapore, Japan, the Hong Kong Special Administrative Region of the People’s Republic of China, and Germany.
We may transfer the information we collect about you to related entities or other third parties, and to other countries or jurisdictions around the world from the country or region you are in. Please note that these countries and jurisdictions may have the data protection laws that are different from those of the country or region you are in. No matter where our servers are, we will take commercially reasonable efforts to take appropriate protection measures to ensure you the rights outlined in this Privacy Policy and any applicable laws and regulations. Therefore, when necessary, we will use appropriate contractual mechanisms (e.g., EU standard contractual terms), rely on the approved international data transfer service providers or adopt binding corporate rules and regulations to ensure data protection.
We have formulated technical, organizational and physical measures to protect your data and ensure your data are in accordance with applicable laws and regulations. We strictly request that only people with legitimate access purposes can gain access to your data. We have also formulated security measures to prevent loss, misuse or modification of the data we process. However, for your understanding, despite our efforts, there is no security measure that is perfectly safe. Please note that we are not responsible for guaranteeing security of the information collected by a third party, and please be sure to refer to the security measures taken by a third party in its privacy policy.
Our Service is not intended for children under the age of 13 (or under the age otherwise required by local laws), and children under 13 (or under the age otherwise required by local laws) should not create any account for the Services. We will not, for any purpose, knowingly collect Personal Information of children under the above-mentioned age. If you believe that we own the Personal Information of the children under this age without the consent of their parents or guardians, or that you are the user’s parent or guardian and wish to withdraw the consent, please contact us with the contact information outlined in "Contact us".
Based on the laws of the country or region you are in, you may have the following rights. If you need to exercise any of your rights, please submit your request via wutheringwaves_ensupport@kurogame.com.
You have the right of access to Personal Information we hold about you, how we use and with whom we share this information. You may access Personal Information you provided to us by logging in to your account.
You have the right to request a copy of certain Personal Information we process about you. This comprises any Personal Information we process based on your consent or the contract we signed with you. You have the right to receive the Personal Information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that Personal Information to another party; however, there can be certain exceptions.
You have the right to rectify any Personal Information we hold about you that is inaccurate. You may access Personal Information we hold about you by logging in to your account.
You can delete or terminate your account, or delete certain Personal Information by logging in to your account. We may need to retain Personal Information if there are valid grounds under applicable laws (e.g., for the defense of legal claims or freedom of expression).
You have a right to request us to stop processing the Personal Information we hold about you in certain circumstances (for clarification, we will then only have right to storage). Please note, however, even if we stop processing the Personal Information, we may use it again if there are valid grounds under applicable laws (e.g., for the defense of legal claims or for protecting vital interest of you or another natural person). As mentioned above, if we agree to stop processing the Personal Information, we will take commercially reasonable efforts to inform any third party to whom we have disclosed relevant Personal Information so that they can also stop processing the information.
You may request us to stop processing the Personal Information we hold about you (for clarification, we will then only have right to storage) where:
a) The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
b) The processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead; or
c) We no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims.
You may exercise control over our collection of Personal Information about you by modifying the browser setting of your device, so as to refuse or disable certain types of cookies. As each browser is different, please refer to the instructions provided for your browser. You may need to take additional measures to refuse or disable certain types of cookies. In addition, your choice to disable cookies is specific to the specific browser or device you use when disabling cookies, and therefore, you may need to disable cookies separately for each type of browser or device. If you choose to refuse, disable or delete cookies, you may no longer be able to use certain functions of the Services.
You have the right to object to our processing of Personal Information about you. You may contact us to send your objection. To the extent required by applicable laws and regulations, we will stop processing your Personal Information.
You may opt out of receiving game update or promotion emails we send to you (if applicable to your region) by following the unsubscription instructions included in these emails, or you can contact us in the way outlined in this Privacy Policy.
You may opt out of receiving Services updates, marketing or advertising text messages by contacting us in the way outlined in this Privacy Policy, and share the phone number that you would like to opt out. For text message, you can also opt out of subscription in the way suggested in the text message received.
When we deem it necessary (e.g., to temporarily suspend access to the Services for server maintenance, security or privacy), we may send you bulletins from time to time. You cannot opt out of subscription of these Services-related bulletins, because they are not of a promotional nature.
Cookies are a type of text files that will be placed into your device when a website is loaded onto the browser. They are widely used to keep websites running or running in a more effective way, as well as to provide information to the website owners or other websites that identify the cookie. When you access our Services, we, a third-party service provider or a partner may use a "cookie" or a similar technology for the specific purposes of (i) providing, developing, maintaining, personalizing, protecting, analyzing and improving our Services; (ii) protecting against, identifying and preventing fraud and other illegal activities; (iii) for us, a third-party service provider and a partner to provide you with personalized advertisement. We will not use cookie or other similar technologies for any purpose other than those outlined in this Privacy Policy. You can manage or delete the cookie according to your preference. For details, refer to AboutCookies.org. You can clear all the cookies saved in the computer, and most of the web browsers offer the function of blocking the cookie.
This Privacy Policy does not apply to any third-party service provider, and we are not responsible for any third-party website or service to which the Services may link. The inclusion of a link on the Services does not imply endorsement of the lawfulness and effectiveness of the linked site or service. When using the linked service, you shall be subject to the service terms and privacy policy of the third-party service provider.
You may use the third-party payment service to make a payment to us by your account on the third-party platform, and in such a way, your Personal Information will be collected by such third parties and not by us and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for this third party’s collection, process, and disclosure of your personal information.
We will update our Privacy Policy from time to time to reflect any changes in technology, law, business operation and other aspects. Any update we make to the Privacy Policy will be notified by an update of the "EFFECTIVE DATE" listed at the top of this Privacy Policy, and the updated Privacy Policy will be released in the Services. If we make significant changes in the way of informing or processing user information, we will also provide additional notice to you (e.g., post the change notice in a significant place on the Services before the change takes effect, or send notice directly to you through email, text message, etc.). We encourage you to check up our Privacy Policy from time to time to look for any new change since your last time of Service access. This will help ensure that you are better aware of your relationship with us, including the way we process your information.
You are encouraged to raise questions, comments and requests regarding this Privacy Policy. Please contact us at wutheringwaves_ensupport@kurogame.com.
Supplementary terms
If you are a resident in the following countries or regions, corresponding specific supplemental terms will apply. If there is any conflict between the text of this Privacy Policy and the supplemental terms applicable to your country or region, contents of the specific supplemental term will take precedence; if not stipulated in the supplemental term, the text of this Privacy Policy still apply.
The United States of America
If you use our Services in the United States, the following supplemental terms apply:
Depending on the region of your residence, you may have certain rights related to your Personal Information; however, there can be certain exceptions. Your rights are as follows:
You may have the right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of information source, the business or commercial purpose for collecting, selling or sharing the Personal Information, and the third party to which we disclose that information.
Despite certain exceptions, you may have the right to obtain a copy of the Personal Information that we collect about you.
You may have the right to request the erasure of the Personal Information that we collect from you or hold about you, but there can be certain exceptions.
You may have the right to request our rectification of any Personal Information we hold about you that is inaccurate.
You may have other choices regarding the use and disclosure of your personal data. You may contact us in the way outlined in the "Contact us" section above to exercise the above-mentioned rights. Under applicable laws, you may have the right to submit a request through an authorized agent. If you need to appoint an authorized agent to exercise the right of choice on your behalf, please issue an authorization letter to the agent. Only if the agent has the valid authorization letter in paper issued by you, will he/she be able to submit the request to exercise the right on your behalf.
We will respond to your request in accordance with applicable laws and through proper means of verification. We will verify your request by asking you to send the request from the email address associated with your account or provide the information required to verify your account. You may offer feedback to us against our decision. Some of the functions and characteristics provided by the Services may change or become unavailable for you, however, you will not be discriminated against for exercising your rights and choices.
Residents in California, the United States of America
In this Privacy Policy, we have thoroughly discussed the specific contents of the Personal Information we collect from users. In the 12 months preceding the effective date of this policy, we have collected all types of Personal Information described in the "How we collect and process your Personal Information" and the "How we share your Personal Information" sections by ourselves or through our service providers, partners and third-party platforms, etc. For more details on the purpose for which we use the information, please refer to the "How we collect and process your Personal Information" section. For information we share with the third parties, please refer to the "How we share your Personal Information" section.
If you are a California resident, you may request us to reveal the categories of Personal Information that we share with third parties for direct marketing purposes. You may submit a request in the way outlined in the "Contact us" section above.
Your browser may offer the "Do Not Track" option, which allows you to signal to operators of websites, web applications and services that you do not want such operators to keep track of certain of your online activities over time and/or on different websites. Currently, our product may not support the "Do No Track" request.
To the extent restricted by applicable laws, we will not sell your Personal Information or share your Personal Information with third parties for the purpose of cross-context behavioral advertising or targeted advertising. Although some of the information we collect may be considered as sensitive Personal Information, we will only process such information while providing Services and within other exemptions under applicable laws, e.g., when we process your sensitive Personal Information for the purpose of performing the Services.
The Republic of Korea
If you use the Services in the Republic of Korea, the following supplemental terms will apply. By continuing to access or use our Services after the release of an updated Privacy Policy, you acknowledge the updated Privacy Policy. If you do not agree with the updated Privacy Policy, you must stop accessing or using the Services. In case of any conflict between the following supplemental terms and the text of this Privacy Policy, the following terms shall take precedence.
Data retention. We will destroy the Personal Information beyond the period of use specified in this Privacy Policy; however, we will continue to store your Personal Information for the following legal periods (if applicable), including but not limited to:
(1) Act on Consumer Protection in Electronic Commerce
l Records of your canceled order, payment for goods purchased and the goods/Services we provided to you: 5 years
l Records of consumer complaints or dispute resolution: 3 years
l Advertisement & label records: 6 months
(2) Protection of Communications Secrets Act
l Records of your access to our website: 3 months
l Destruction of Personal Information. We will destroy your personal data in a way that cannot be restored by relevant department.
l Data rights. You have the right to access the Personal Information that we hold about you, correct any Personal Information about you that is inaccurate, request the deletion of the Personal Information we hold about you, and request the suspension of the processing of your Personal Information.
You may contact us in accordance with the "Contact Us" section for exercising your rights.
Data security. We seek to protect KURO GAMES and our users from suffering unauthorized access or unauthorized modification, disclosure or destruction of the information that we hold. To this end, we have formulated technical, organizational and physical measures, including internal data protection policies, to limit access to Personal Information and control access to devices processing Personal Information to the minimum scope of necessity.
Information related to children. Our Services are not intended for children under the age of 14.
The commission and/or overseas transfers of Personal Information. We commission your data to our affiliated companies, cloud storage service providers, IT service providers and data centers, some of which are located overseas. The entity that receives and processes your data is committed to using and storing Personal Information in accordance with the international laws and regulations and those of the Republic of Korea, and to take physical and technical measures available to protect Personal Information. So long as the transfer is not necessary for providing Services to you, you may choose to decline such transfer by contacting us under "Contact us" section.