Effective Date: 2023. 12. 01

1. Introduction

KRAFTON, Inc. and/or its affiliates(“we”, “our”, “Company” or “us”) collect, use and process information about you (“you” or “user”). We provide various services related to our app, website, event, survey, or customer service("Services"). This Privacy Policy (“Policy”) covers the personal information that is provided, collected, or generated when you access, use or subscribe to our Services, except where separate privacy policies or terms and conditions apply. This Policy applies to our Services, and also explains the rights and choices you have with respect to this data, and how you can communicate with us. This Policy does not apply to and cannot control activities when you click or visit to other sites from our Services.

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

2. What Information Do We Collect

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

1) Identifiers, such as nickname, name, IP address, email address, social media information (*), date of birth, etc.,

2) Internet or other electronic network activity information, such as browsing behavior while using our Services (i.e. device model, OS version, MAC address, device ID, advertisement ID, etc.),

3) Service information, such as setting, etc.,

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

(*) When you access our Services using your platform account, we collect certain information from the third-party platform provider, such as your platform profile/account, consistent with the terms of the third-party platform and your privacy settings thereon.

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

3. How We Use Your Information

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

1) To operate and provide our Services;

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

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

4) To manage inquiries and requests from you;

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

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

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

8) To comply with and enforce legal requirements, agreements, and policies; and

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

4. How We Share Your Information

We share certain personal information with third parties to provide our Services to you, including service providers that process personal information on behalf of us to provide our Services to you, like customer support and to manage our community. Some examples of these third parties are provided below.

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

2) marketing platforms and providers of analytics services relating to user behavior, in order to tailor the Service and to conduct marketing activities;

3) online survey service providers in order to improve Services;

4) customer service providers to answer users’ inquiries;

We may share your information where such disclosure is essential to comply with a legal obligation or a lawful data access request, pursuant to a merger or acquisition, or where you have otherwise provided your consent or at your direction.

5. Cookies and Related Technologies

We use cookies, and other technologies to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes. Approved third parties may also set cookies and related technologies when you use our Services.

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 our websites 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. Ads appearing on our websites may be delivered to you by third-party advertising companies. These companies may use information about your visits to our websites in order to provide advertisements to you and other sites about goods and services that may be of interest to you.

2) Website Analytics

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

We use Google® Analytics, provided by Google Inc., which collects personal data and uses cookies for reporting purposes. You can withdraw your consent by adjusting Google's advertising settings (https://myadcenter.google.com/) and learn about Google’s privacy policy at https://policies.google.com/privacy. Opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

We also incorporate AdMob by Google which allows us to manage and optimize our ad inventory by employing cookies and gathering personal data. For opting out, visit Google's ad settings (https://myadcenter.google.com).

3) App Analytics

Our mobile applications utilize analytics services for app usage insights and ad optimization.

IronSource helps us to understand app usage and optimize user experience. You can opt-out by adjusting your privacy settings within the app or on the IronSource website(https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/). We use Adjust to gather insights into user behavior on our websites. Adjust collects personal data and employs cookies for analytical and reporting purposes. For more information on Adjust's privacy practices and how to opt-out, visit their website(https://www.adjust.com/terms/privacy-policy/)

6. International Data Transfers

The access to your personal information is limited to our employees, agents and contracted third party, who are bound by strict confidentiality agreements and have access only on a business need to know basis. No one can access your personal information without our approval. However, we may electronically transfer your data, secured through multiple layers of security, communicated using leading encrypted technologies, to contracted third party service providers, who may be in different country or region, to operate the service and/or to meet any legal requirements. The legal basis for such processing is compliance with a legal obligation to which we are subject to or are legitimate interests, such as exercise or defense of legal claims. In the event of transfer to another country or region, we will take steps to ensure that your information receives the same level of protection that is adhered to as provided for under Indian laws.

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 user.

8. Our Policy Concerning Children

We do not knowingly collect, use or share any sensitive and personal information about underage users(age rating depends on the country where you reside) without verifiable parental consent or as permitted by law. If you are a parent or guardian and you believe your child has provided us with the 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 our website and go to the website you selected. Because we cannot control the activities of third parties, we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to our 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 protect your personal information. In addition, we limit access to your personal information to those employees, agents, persons, or companies who have a business need to know or access the information. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality where appropriate. Please note, however, that no data transmission over the internet is 100% secure, and that complete security of any information we collect and use therefore cannot be guaranteed.

Annually we audited by external authorities for its information protection activities through Korean information security standard ISMS-P(Personal Information & Information Security Management System).

11. Your Privacy Rights

Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, 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 “13. 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.

12. Amendments

We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Services. All other changes are effective upon posting.

13. Contact Us

If you have any questions about this Policy, or your dealings with our services, please contact us by using one of the following communication channels.
Grievance Officer Information
- Name: Sanket Sarkar
- Contact: archeryking_india_support@krafton.com

Appendix. 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 using our Services, and the rest of the Policy, the relevant jurisdiction’s Supplemental Terms - Jurisdiction Specific will supersede and control.

For a user in India

If you are a user in India, for any issues in relation to the collection and processing of your personal data, you may reach out to our Grievance Officer(“13. Contact Us”). The Grievance Officer will respond to your concerns and queries at the earliest and in compliance with applicable law.

1) Our Policy Concerning Underage Users
We do not knowingly collect, use or share any personal information for those who are under 18 years of age without the consent and verification of the underage users’ parent or guardian, or unless permitted by law. If you are under the age of 18 years, you will be asked to provide the mobile phone number of your parent or guardian to confirm that you are legally eligible to play the Service. If you are a parent or guardian and you believe your child under 18 years of age has provided us with their personal information without your consent, you can contact us and request that your child’s information be deleted from our system

2) Sensitive Personal Information
We can collect sensitive information (payment information, Proof ID number, etc.) while we are operating our Services. We collect or process your sensitive personal information after you give us consent.