PLAYERUNKNOWN’S
BATTLEGROUNDS MOBILE
Privacy Policy
Last Updated: September 12, 2024
Thank you for
using Proxima Beta’s (as defined
below) products and services! We respect your concerns
about privacy and appreciate your trust and confidence in us.
Here is a summary of the information contained in this privacy policy.
This summary is to help you navigate the privacy policy and it is not a
substitute for reading everything! You can use the hyperlinks below to jump
directly to particular sections.
What information do we need to provide the
Game Services?
If you register an account to use the Game then we will need some
information from you to set this up. We will also process some information when
you use the Game (e.g., to make sure your progress is saved) and when you buy
items (e.g., to ensure you get the purchased content). If you choose to
set up your Game profile using a social media account, we also collect
information from that social media account. If you choose, you can provide
certain other information to personalise the gaming experience and enable Game
features, or participate in Game Services. If you choose to use the
eSports Website, we will need your Game login credentials and other
information, such as your email address, user and account information, and
information to enable you to form or join teams and participate in eSport
competitions for the Game. If you need to get in touch with us then we will
also retain some information so that we can get back in touch with you and
address any concerns. More Information.
How will we use your information?
We use your information to provide the many
functions and services that comprise the Game Services. We also use
your information for account verification, security purposes, to support and
improve the Game Services, to process transactions as part of the Game
Services, to provide you with game updates, and to enforce our terms,
conditions and policies. We do not disclose your information to any third parties, except where we need to in order to
provide the Game Services (e.g., use local cloud providers or to back up your data;
using our affiliates around the world to help us to deliver the Game Services)
or monitor the success of our marketing and advertising programs, or where we
are instructed to by a court, authority or compelled by law. More Information.
Who do we disclose your information to?
We use some third parties to help us deliver the best possible
experience (e.g., cloud services to back up your data, support ticketing and
fraud detection). When we use a third party, we only do this to process or
store your information for the purposes described in this privacy policy. We
also have affiliates around the world who help us deliver the Game Services and
we may be required by a court or legal obligation to disclose certain
information in some circumstances. More
Information.
Where do we process your information?
Our servers are located in Russia (in the case of users located in
Russia only) and Singapore. Your information can be accessed from outside of
where you live by our support, engineering and other teams around the world,
including Singapore, the People’s Republic of China, Egypt, Turkiye, Malaysia, Brazil
and Mexico. More Information.
How long do we keep hold of your information?
We generally retain your information for the period during which you
maintain an account for this Game after which time
your data is deleted (as further described in this privacy policy), unless
otherwise required by applicable laws. More Information.
How can I exercise my rights over my information?
Depending on where you live, you may have certain rights with respect to
your information, such as rights of access, to receive a copy of your data, or
to delete your data or restrict or object to our processing of your data. More Information.
How to get in touch with us
If you have any questions about anything in this policy, or want to
exercise any rights you may have, please contact us here.
How will we notify you of changes?
If there are any significant changes to this privacy policy, we will
update the policy here. More
Information.
Data Controller: Proxima Beta Pte. Limited | Email: dpo@proximabeta.com
EU Representative: Proxima Beta Europe B.V. | Email: dpo@proximabeta.com
UK Representative: Image Frame
Investment (UK) Limited | Email: dpo@proximabeta.com
Serbia Representative: Karanovic
& Partners o.a.d. Beograd. | Email: local.representative@karanovicpartners.com
Thailand Representative: Tencent (Thailand) Company Limited | Email: dpo@proximabeta.com
Türkiye Data
Controller Representative: Özdağıstanli Ekici Avukatlık Ortaklığı. |
Email: turkeydatarep_proximabeta@iptech-legal.com (Özdağıstanli Ekici Avukatlık Ortaklığı is our data
controller representative and its authority is limited to the authorities
stipulated under the Law on Protection of Personal Data w. no 6698.
Özdağıstanli Ekici Avukatlık Ortaklığı is not authorized for any other matters
such as in-Game conduct, suspensions, investigations, civil or criminal
complaints.)
Welcome to PLAYERUNKNOWN’S BATTLEGROUNDS
MOBILE!
This
privacy policy explains the when, how and why when
it comes to the processing of
your personal information in connection with the mobile game PLAYERUNKNOWN’S BATTLEGROUNDS
MOBILE (“Game”), the website for the Game (“Website”) and the
eSports Website for the Game (“eSports Website”) (the Game, the Website
and the eSports Website together comprise the “Game Services” and the
Website and the eSports Website together comprise the “Websites”),
and sets out your choices and rights in
relation to that information. Please read it carefully – it is important
for you to understand how we collect and use your information, and how you can
control it.
If you do not agree to the processing of
your personal information in the way this privacy policy describes, please do not provide your information when
requested and stop using the Game Services. By using the Game
Services, you are accepting our rules regarding your personal information as
described in this privacy policy.
This Game has been developed
by Proxima Beta Pte. Limited (“we”, “us”, “our”, or “Proxima Beta”).
For the purpose of data protection
laws, the data controller of your personal information in relation to the
Game Services is Proxima Beta Pte. Limited. The registered address
of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International
Plaza, Singapore.
Our data protection officer can be
contacted at dpo@proximabeta.com.
Our representatives for
data protection purposes in certain jurisdictions are as follows:
|
EU |
Proxima Beta Europe B.V. |
Buitenveldertselaan 1-5, 1082
VA, Amsterdam, the Netherlands |
|
|
UK |
Image Frame Investment (UK)
Limited |
4th
Floor 80 Strand London WC2R 0RL |
|
|
Serbia |
Karanovic & Partners o.a.d. Beograd |
Resavska 23, Belgrade, 11000,
Serbia |
local.representative@karanovicpartners.com |
|
Thailand |
Tencent (Thailand) Company Limited |
8 T-One Building, Floor 10th, 11th & 12th (Unit
3-5), Soi Sukhumvit 40, Sukhumvit Road,
Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand |
|
|
Türkiye |
Özdağıstanli Ekici Avukatlık
Ortaklığı. |
Nidakule Ataşehir Kuzey Begonya Sok. No:3 Kat. 17 D: 162 34746 Ataşehir / İstanbul,
Türkiye Özdağıstanli
Ekici Avukatlık Ortaklığı is our data controller representative and its
authority is limited to the authorities stipulated under the Law on
Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık
Ortaklığı is not authorised for any other matters such as in-Game conduct, suspensions,
investigations, civil or criminal complaints. |
turkeydatarep_proximabeta@iptech-legal.com |
Please reach out to us if you have any
questions or concerns regarding the processing of your personal information:
you can contact us anytime at dpo@proximabeta.com.
1. The Types of Personal Information We Use
This section describes the different types
of personal information we collect from you and how we collect it. If you would
like to know more about specific types of
data and how we use that data, please see the section entitled “How We Use Your Personal Information” below.
The following is a high-level summary of
the types of personal information we use:
1. Information you provide to us (either directly or
through a third party).
You give us information about you when you
register for the Game (your nominated nickname, and information we import from
your connected social media account (WeChat, Facebook, QQ, VKontakte, Twitter,
Google Play, Game Center or LINE) in order to set up your profile, including
your name as it appears on your social media profile, your user ID and your
profile picture). For certain regions, you may also be asked to provide us with
your date of birth (stored device-side only) to verify your age and for administration
of the gameplay management system. If you are located in certain regions, we
may ask you to provide an email address for the purpose of verifying parental
or guardian consent to use the Game services if you are under the relevant
minimum age. You also provide us with information when you set up your profile
for the Game (including region location and information you voluntarily elect
to provide in order to customise gameplay or Game Services, such as gender or
photos you upload to your in-Game photo wall) or your nickname when you log-in
as a ‘guest’ in order to use the Game.
Once a Game account is set up, you may
also choose to provide us with your mobile phone number or email address and a
password, which you may select yourself for these purposes. These will be bound
to your account (once verified by way of a verification code we will send to
you) for the purposes of enabling login by email or mobile phone number. If you
choose to bind your phone number or email address with your account, you will
have the option to login via your mobile phone number or email address and we will
access your phone number or email address to verify you as a user without you
having to enter a validation code or password every time you login. If you
choose to bind your phone number, you can also enable two-factor
authentication. Once enabled, we will verify additional data for authentication
if you log in from a new device. If you choose to bind your email address, we
will send an account security alert to your email address if we detect any
suspicious activity. If you need to recover your account, we will ask you
questions to verify your identity. If you would like to be featured on
leaderboards, you will also be asked to bind your mobile phone number. For
certain regions, we will ask you to bind your telephone number with your
account when you change your location setting.
In addition, you may choose to provide
your location (province and city) to use region-specific features, for example,
our Battle Zone Leaderboard, People Nearby, Regional Chat Channel and birthday
features. If you would like to use our birthday features, you may provide your
birthday (month and day) and location. You may add your in-game weapon
preferences, game mode preferences, voice chat preferences, audio
self-introduction and any other information to your calling card and share your
calling card and QR code with other players, if these functions are available
in your region. You also provide us with information when you participate in a
survey in the Game (in which case we will process the information you provide
to us as part of the survey, which may include (amongst other information) your
gender, age or age range, country or region of residence, income, education,
occupation, contact information, nickname). When you participate in one of our
sweepstakes events, which may be conducted in-Game, on our Website or
otherwise, you provide us with information including email address, user ID,
phone number, mailing address and country; when you register for a tournament,
we will collect your name, email address, country/region,
user ID, photo, and team name and team photo (if applicable); and when you register for an e-sports event or community
event, we will collect (as applicable) your team name, registration region,
team logo, your name, nationality or residency, email address, phone number, Discord
ID (if applicable) and user ID. If you qualify to attend in person an e-sports or
community event, we may also ask you for your ID or passport information, date
of birth, gender, home address, phone number, photo and social media profile.
If you participate in tournaments or e-sports events, we will use your
user ID, nickname, battle videos and audio and video recordings during matches to
validate that you are the correct Game user, to investigate any allegation of
cheating and for marketing and promotion. In some
instances, we may also take photos and videos of, and/or video record and/or
livestream tournaments or events that you participate in, in which case certain
data relating to you or your team and videos of you will be processed, captured
and displayed on public platforms. We may also retain photos and video
recording of the tournament or event for publicity and marketing purposes, and
to improve our Game Services. If you are suspended from participating in
tournaments or e-sports events for cheating or otherwise violating tournament
or e-sports event rules, we use your name, Game nickname (including variations)
and day and month of birth to enforce the suspension and may publish your nickname, the reason for the suspension and
the duration on our Websites or social media channels. If you participate in one of our events (including game-based
events), to send you digital prize(s) if you win such prize(s), we will process
your email address and telephone number; to deliver physical prize(s) if you
win such prize(s), we will process your name (as shown on your passport), team
name, email address, telephone number, mailing address and postal code; to
deliver cash prize(s) if you win such prize(s), we will process your name (as
shown on your passport), email address, telephone number, and payment
information (or payment may be made to your club or team bank account, as
applicable); and if you share the event with your friends, we will process your
friends list.
You provide us with your telephone number
and/or email address and/or associated social media account information if you
choose to receive information on our game updates via email and/or SMS and/or
social media. Where applicable to your region, you
provide your email address if you choose to
receive information on our game promotions via email. You also provide information when you interact
with a Q&A function or with our customer service team, including your
contact information, any questions and images you submit and your social media
platform information. For data subject requests, we collect information to
verify your identity, your rights and to process the requests, including
country/region, name, user email address, screenshot of user ID and user nickname,
user ID, account registration date, login method, user nickname of linked
social media account, account UC balance, account BP balance, request details,
any other information necessary to verify your identity, and if the request is
made by a requestor on your behalf, name of requestor, email address of
requestor, requestor's relationship with you, proof of your identity and
requestor's authority.
If you use the eSports Website, we need
your Game login credentials to enable you to
access eSports Website, your user registration
information and account binding information to allow you to register as a
player on the eSports Website and to participate in eSports events and team
information to facilitate formation of teams.
If you would like to participate in Website events (if
available in your region), we use your social media account information or
email address to set up your account and your event registration information to
register you for an event. If you win a prize at a Website event, we use your
hashed nickname to announce your win and, in case of (i) an in-Game prize, your
user ID to deliver your prize; and (ii) a physical prize, your contact
information to deliver your prize.
2. Information about you generated as part of the Game Services
We automatically collect certain data from
you when you use the Game Services, namely your user ID, country/region,
nickname, language, IP address, device information (such as application
version, battery level, WiFi strength, available space, list
of installed applications, network
type, OS version, platform, carrier, country code, series ID, Android ID, IDFV,
XID (if you are a guest user, generated from your
existing device information, model, manufacturer, Android ID), WiFi SSID
(stored device-side only) and time zone settings),
registration time, login time and status, battle and performance information,
and information regarding your use of the Game
Services, such as date and time stamps of actions. We also collect and store
your data:
·
each time
you interact with us, for example, when you use in-app or in-Game support to
communicate with us;
·
if you
choose to log in using a social media service, we import the social media user
ID and name of the friends (and in the case of Facebook, their Facebook
nickname and profile picture) from your social media profile so that you can
connect with your friends, invite them to team
up and share game activities with your friends;
·
if you
click on a link that advertises the Game, we store the Advertising ID for that advertisement
and select device information with your profile;
·
if you
enable chat services (audio and/or text and use them whether inside or outside
a battle) then we will process such data in order to deliver your messages to
other users;
·
if you
conduct any transactions within the Game or via a third party other than Google
Play or iOS App Store, we collect information to facilitate your transaction
and to maintain transaction records (including user ID, country and user information, cost, currency,
product purchased, purchase history, IP address, details of transactions linked
to user ID, and device details such as IDFV, network type, network
monitoring data, client exports IP, SDK version, application version, OS version, phone model or type of device, internet
connection) and use transaction identifiers to detect
fraud;
·
if you
request for a refund, we use your transaction ID, delivery status, consumption status, refund recommendation and user
account flag to help inform and improve the refund process;
·
if you
change your location setting, we use your IP address to suggest your current
location;
·
if you
have poor network connection, we collect your routing information to analyse
the cause to allow you to play the game;
·
if you
qualify for a tournament, we use your user ID to invite you to participate;
·
if you
take an in-Game screenshot, we process such data (device-side only) to
facilitate your sharing of the screenshot on social network;
·
if you
enable our highlights replay function, we use your Game operation records,
nickname, profile picture and ranking information to provide highlights replay
videos that you can share;
·
if you
are a highly-ranked player, your battle replay video may be featured as part of
the highlights showcased from time to time in-Game;
·
if you
choose to participate in our Beta test, the following information is used to
verify your eligibility: your login credentials, user ID, account type, Game
level, frequency of use of Game, whether your Game account is bound to a Beta
test account, and whether you have cheated in the Game;
·
for users
in certain regions, if you participate in a group photo event, we process the
photo you upload (processed device-side only), the photo generated (processed
device-side only), your user ID and your election to share the photo generated;
·
for users
in certain regions, if you create or join clans,
share or view picture, text or video content, comments or other posts, create
or join custom matches, tag content, follow creators, give or receive gifts or otherwise use or
customize the Club features: (i) we process your user ID, avatar, rank, country
and region, province, city, language, nickname, friends list, joined clans,
game title, custom room game data, eligibility tag, gift records, popularity,
game props owned and bookmarked, follows, picture, text and video content, likes,
comments or other posts you share publicly in the Club or with other clan members, social media links and creator profile and
statistics; (ii), we will process your user ID,
social media account nickname and content if
you choose to showcase content posted on your social media account in-Game; (iii) our content audit feature will detect if any picture, text and video
content you share in the Club or with other clan members contains pornography
or other content that violates the Community Guidelines or the End User License Agreement and remove content in such cases; (iv) we will process your user ID, carrier, network type, WiFi status,
device model, operating system, operating system version, frame rate, page load
time, memory information, exception error and stack, exception log to
optimize the performance of the Club functions and provide a better user
experience;
·
if you apply to be a
reviewer of user-generated content and/or become a reviewer, we process your
nickname, user profile, avatar, user ID and Facebook ID;
·
if you share replay
videos with your friends on your Moments page, we process your nickname, avatar
and any replay videos generated
with game operation records that you share;
·
if you add event
schedule information to your system calendar, this is provided device-side
only;
·
for users
in certain regions, when you are using the Game Services, we collect your daily
cumulative gameplay time and your daily rest time to prevent gaming addiction;
·
for users
in certain regions, we collect your game data, performance data and user
preference information to understand your skill levels and preferences, and provide a better user
experience;
·
if you
contact our support team or use our Q&A function, we collect information
including name (optional), user ID, nickname, country/region, device ID and
other device information, login channel ID, application version, SDK version,
battery level, WiFi strength, free space on device, IP address, network type,
OS version, browser type, Game server, platform, carrier, country code, language, source of ticket, details of
ticket, number of visits, social media platform information, ID and nickname
(if used to login to the Game), profile picture, birthday (day and month),
account status (whether an account is suspended and if so, since when, reason
for the suspension and game statistics), email address (optional if
in-app/in-Game support), phone number
(optional), registration time, VIP level, game
duration, historical records, items, currency, penalties, logins, activities,
recharge, purchases, in-game friend relationships, game match data and any question or
information that you provide in your communications. You also have the option
of providing a photo to illustrate any errors;
·
when you
enter specific pages (such as the contact page), when you click on certain
features (such as to chat or buttons to submit requests or ratings), when you
submit related information (such as ratings) and when you view pages and read
messages;
·
when you
are using the Game Services our security feature collects (in addition to the
categories of data listed above) device information including OAID, IDFV,
Android ID and available memory; and a list of installed APK and running apps;
·
when you
are using the Game Services, our security and anti-cheating security features
(i) monitor users to identify and observe cheating behaviour; (ii) collect (in
addition to the categories of data listed above) user’s in-Game instructions to
generate an in-Game behavior video clip of suspected cheating behaviour for our
review; (iii) detect if your profile picture is related to the sale of plug-ins
or pornographic content and change it to a default profile picture if this is
the case; (iv) identify abuse, harassment, the sale of plug-ins or other
conduct in violation of our End User License Agreement and restrict your use of the chat functions where you
have engaged in any of the foregoing if this is the case as well as, if
applicable to your region, improve tools used for this; (v) detect if your
signature, nickname, profile photo, photos, free text, chat history, audio
self-introduction or other user-generated content contains malicious
information or other content that violates local laws or the End User License Agreement and to block the content or change it to its default
setting and prompt you to change it subsequently, as applicable; (vi) detect if you are using tools to cheat, take
screenshots where there is suspected cheating behaviour for our review and
restrict your use of the Game if this is the case; (vii) review real-time games
of users suspected of cheating; (viii) review in-Game video clip and Game data
if we receive a complaint about cheating and (ix) review, analyse and combat
cheating;
·
if you are restricted from accessing the Game and/or using the chat
function, we process your user ID, reason and
duration of suspension to notify you and to enforce suspensions and/or
to reduce the duration of suspensions;
·
if you
participate in one of our game-based events and file a report or complaint, we
may screenshot your in-Game view to facilitate our review of your complaint
(though you may choose not to upload the screenshot);
·
if you share user-generated maps, we process your
creator certification information, user information and map information;
·
if you use in-Club UGC map services (if available in your region), we process map tags, map IDs, creator tags, pins and recommendations to facilitate interaction between creators and players;
·
if you interact with World of Wonder creations, we process your gameplay
records of World of Wonder creations, in-Game friends and in-Game avatar to
facilitate friend interactions;
·
if you participate in our World of Wonder (WOW) Incentive Program, we
process your user ID, open ID, avatar, creation code ID, and creation data (including total play count, likes, follows) to
provide the WOW Incentive Program, to evaluate whether you are eligible for
rewards, and to distribute such rewards (if applicable and available);
·
if you are a World of Wonder player, we process certain user preference information
to understand your interests and improve our advertising and marketing programs;
·
when you
interact with friends, we process your nicknames and interaction information such as
time of becoming friends in-Game, number of times you invited each other to
form teams, number of times you formed teams with each other, number of times
you rescued each other to
facilitate friend interactions, to operate and manage team activities and
achievement progress, and, if enabled, to send you push notifications about
friend interactions;
·
when you use our Ptopia Design Project platform, we process your login
information, personal homepage information, application information, cookie
information, content information, like and comment information, participation
information, voting information and reward information, as applicable;
·
when you
use the eSports Website, we process your user ID and chat message to deliver
your message to your team members if you chat with them, detect and remove any
content that contains pornography or which otherwise violates the End User License Agreement and process your user ID send you notifications about
the eSports Website services; and
·
if you participate in Game competitions on the FACEIT
service, we will share your user ID and match results with FACEIT to facilitate
your use of the service.
3. Information you generate and display in the course
of using the Game Services.
You may provide additional information as
part of your profile (such as gender). You may also provide or generate
information when you communicate with other users (chat log data and chat
content, both audio and text). We generate a user ID and use this to store your
Game data, and we collect and store your Game play statistics (e.g. level,
scores) in order to provide you with feedback, information about your Game play
and progress. If you participate in a sharing event, we will process your Game
data (prop types, wins, ranking and Game play statistics) to prepare a report
for you and process your friends list so you can share Game activities with
your friends. We use your combat and team data to prepare season and
anniversary reviews for you and to enable you to share such information with
other players if these functions are available in your region. Your Game data and country/region are also used to
determine if you qualify for, and to invite you to participate in, a
tournament.
4. Beta features.
You may have the opportunity to use “beta”
features for a limited period of time. These may be accompanied by a notice or
flag indicating that they are in “alpha”, “beta”, “test” mode, or similar.
These features are made available to help us test new ideas and improvements
for the Game. By agreeing to participate in a beta, you understand that we may
process data as part of these features in order to ensure the features can
function properly and (once the beta period has concluded) to understand
whether it makes sense to modify or rollout those features to the broader
community. We may also seek your feedback so that we can understand your
experience of the features. We will only process personal data for so long as
is necessary for us to fulfil these purposes, and thereafter will take steps to
delete or de-identify your personal information (including any feedback you
provide).
Cookies
We use cookies and other similar
technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”)
to enhance your experience using the Game Services. Cookies are small files
which, when placed on your device, enable us to provide certain features and
functionalities.
You have the option
to permit installation of such Cookies or subsequently disable
them. You may accept all cookies, or instruct the device (in the case of the
Game) or web browser (in the case of the Websites) to provide notice at the
time of installation of cookies, or refuse to accept all cookies by adjusting
the relevant cookie retention function in your device. However, in the event of
your refusal to install cookies, the Game Services may be unable to
operate as designed.
For more information about our Cookies
policy, click here.
Children
Our Game Services are not intended for
children. Children must not use the Game Services for any purpose, except where
their parent or guardian has provided consent (to the extent this option is
available in your jurisdiction). By children, we mean users under the age of 18
years old; or in the case of a
region where the minimum age for processing personal information differs, such
different age. For users located in certain regions we have listed the minimum
relevant age in the table below.
|
Region in which the user is located |
Minimum age of the user |
|
Algeria |
19 |
|
Argentina |
13 |
|
Australia |
18 |
|
Bangladesh |
18 |
|
Brazil |
18 |
|
Cambodia |
18 |
|
Canada |
13 |
|
Colombia |
18 |
|
Egypt |
18 |
|
European Economic Area |
16 |
|
Hong Kong |
18 |
|
Indonesia |
21 |
|
Kazakhstan |
18 |
|
Kingdom of Saudi Arabia |
18 |
|
Kuwait |
21 |
|
Macau |
18 |
|
Malaysia |
18 |
|
Mexico |
18 |
|
Morocco |
18 |
|
Myanmar |
18 |
|
New Zealand |
16 |
|
Nigeria |
13 |
|
Philippines |
18 |
|
Qatar |
18 |
|
Russia |
14 |
|
Serbia |
15 |
|
Singapore |
13 |
|
South
Africa |
18 |
|
Switzerland |
14 |
|
Sri
Lanka |
18 |
|
Thailand |
20 |
|
Tunisia |
18 |
|
Türkiye |
18 |
|
United Arab Emirates |
21 |
|
United Kingdom |
13 |
|
United States |
13 |
We do not knowingly collect personal information from children under these ages
for any purpose. If you believe that we have personal information of a child
under these ages without
parental or guardian consent, or
if you are the parent or guardian of the user and wish to withdraw the consent,
please submit your request at https://www.pubgmobile.com/datasubject
or contact us at dpo@proximabeta.com and
we will delete such information.
2. How We Use Your Personal
Information
This section provides more detail on the
types of personal information we collect from you, and why. For users who live
in the United Kingdom, the European Economic Area, Switzerland, Thailand,
Indonesia, Brazil or Türkiye (each, a “Relevant Jurisdiction”), it also
identifies the legal basis under which we process your data.
|
Personal
Information |
Use |
Legal Basis (only relevant if you are located in a
Relevant Jurisdiction) |
|
Game |
||
|
Information you provide to us (either directly or through a third party) |
||
|
Nickname |
We use this information to create your account for the Game in
accordance with your request. |
Necessary to perform our contract with you to provide the Game. |
|
Hashed Nickname |
If your account is determined to breach our End User License Agreement or otherwise is found to be undertaking activity which is illegal,
defamatory, damaging to the platform or similar, and your account is
consequently suspended, we may publish a hashed version of your nickname on
our Website and in the Game (including via in-Game pop-up). |
It is in our
legitimate interest to ensure the security of our services and to maintain a
fair gaming environment within the Game, including notifying other players if
a participant has been removed for behavior that violates the End User License Agreement. |
|
Social Connect Information (if you choose to log in via your social media
account with these networks):
|
We use this information to: · create your account
for the Game in accordance with your request; · disclose in-game
photos on WeChat, Facebook, VKontakte, QQ, Twitter, Google Play, Game Center
or LINE (as applicable) at your request; and • provide a Q&A function and manual
customer service (on Facebook and LINE). |
Necessary to perform our contract with you to provide and support the
Game. |
|
Gender (if you
elect to provide this information to customise gameplay) |
We only receive this information if you voluntarily provide it (other
than users who log in via their QQ or WeChat social media account, when
gender is also collected – please see above). It is used in order to
customise gameplay. |
Necessary to perform our contract with you to provide the Game with
gender-specific content in accordance with your request. |
|
Gender Information: user ID, nickname, gender (if you elect to
provide this information for display as part of your profile) |
We use this information to enable you to display gender information as
part of your profile if you voluntarily provide your gender for this purpose. |
Necessary to perform our contract with you to allow you to display
gender information as part of your profile. |
|
Date of Birth (not stored) |
We use your date of birth to verify your age if you are a user in
certain regions. This is processed device-side only and is not transferred to
us. |
N/A. |
|
Email address (for verification
of parental or guardian consent) |
If you are located in certain regions,
we may ask you to provide an email address for the purpose of verifying
parental or guardian consent to use the Game services if you are under the
relevant minimum age. |
Necessary to perform our contract with you to
provide the Game. |
|
Region Location (manually selected by you) |
We use this information to: ·
verify your region
location; ·
set up your
gameplay on a regional server; ·
provide you with
your geographic ranking; and ·
improve gameplay. |
Necessary to perform our contract with you to provide the Game. |
|
Friends List (WeChat, Facebook, QQ, VKontakte, Twitter) |
If you choose to log-in using a social media service, we import the
social media user ID and name of the friends from your social media profile
so that you can connect with your friends and share game activities with your
friends. If you choose to log-in through Facebook, and connect with your
friends that also have the Game, we import the Facebook nickname and profile
picture of those friends. |
Necessary to perform our contract with you to provide the Game and
connect you with your friends. |
|
Friends List (manually added by you) |
We use this information so that you can connect with your friends and
share game activities with your friends. We also use this information to display the number of mutual friends
you have with other players. |
Necessary to perform our contract with you to provide the Game and
connect you with your friends. |
|
Telephone number and/or email address and/or
associated social media account (if you elect to provide this
information to receive game updates or, where applicable to your region,
promotions). In relation to your telephone number, this includes your
telephone number, country code and SMS content (“SMS Sending Records”) |
We use this information to send you verification codes or information
on our game updates via SMS or email. Where applicable to your region, we may use your contact information
to send you information on game promotions and activities. |
To the extent applicable and permissible in the
Relevant Jurisdiction(s), it is in our legitimate interest to provide you
Game updates and promotions. Otherwise, we collect this information with your
consent. |
|
Telephone number and email address |
We use this information to provide a Q&A function and manual
customer service (via email and/or social media or messaging platforms such
as WhatsApp, Facebook Messenger, LINE). |
Necessary to perform our contract with you to provide and support the
Game Services. |
|
Email address (if you elect to provide this information to bind your account with
your email address) |
We only receive this information if you choose to
enable login by email address (once verified by way of a verification code
sent to you). |
Necessary to perform our contract with you to provide the Game using
your email address. |
|
Telephone number (if you elect to provide this information to bind
your account with your telephone number). This includes SMS Sending Records |
We only receive this information if you choose to
enable login by mobile phone number (once verified by way of a verification code sent to
you). |
Necessary to perform our contract with you to provide the Game using
your phone number. |
|
Two-factor authentication information: telephone number, email address (optional), device ID, device model. This
includes SMS Sending Records |
If you choose to bind your phone number and enable two-factor
authentication, we use this information for verification when you log in from
a new device. |
Necessary to perform our contract with you to enable two-factor
authentication. |
|
Telephone number and User ID (if you elect to be featured on leaderboards). In relation to your
telephone number, this includes SMS Sending Records |
We use this information to bind your account with
your telephone number and send you SMS verification codes if you would like
to be featured on leaderboards. |
It is in our legitimate interest to ensure the security of our
services and to maintain a fair gaming environment within the Game. |
|
Telephone number (when you provide this information to bind your account with your
telephone number to change your location setting in certain regions). In
relation to your telephone number, this includes your telephone number and
country code |
We use this information for the purposes of enabling
login by mobile phone number if you choose to change your location setting in
certain regions. |
We collect this information with your consent. |
|
Location information (province and city manually
selected by you) and nickname |
We use this information if you voluntarily provide
this to enable your use of region-specific features, for example our Battle Zone
Leaderboard, People Nearby, Regional Chat Channel and birthday features. |
Necessary to perform our contract with you to provide region-specific
features. |
|
Birthday feature information: user ID, birthday (month
and day), location information |
We use this information if you choose to display
your birthday and location information to other players. |
Necessary to perform our contract with you to provide birthday
features. |
|
Game-based Event Information (digital prizes): email address and telephone
number |
If you participate in a game-based event, we use your contact
information to send you your prize if you win. |
N/A. |
|
Game-based Event Information (physical prizes): name (as shown on passport),
email address, telephone number, mailing address and postal code |
If you participate in a game-based event, we use your contact
information to send you your prize if you win. |
Necessary to perform our contract with you to deliver your prize. |
|
Game-based Event Information (cash prizes): name (as shown on passport), email
address, telephone number, payment information (bank account number, bank
swift number, bank billing address) If
you are eligible to win a cash reward, in certain instances you may also be
directed to Freelancer to claim your cash reward . Your
user ID and OpenID will
also be shared with Freelancer. You
can also read more in the Freelancer privacy policy available here. |
If you participate in a game-based event, we use your contact
information to send you your cash prize if you win. |
Necessary to perform our contract with you to deliver your prize. |
|
Calling Card Information: user ID, profile information, in-game
preferences, audio self-introduction, generated QR code (including camera
permission and photo album permission) and any other information you share in
your calling card |
We use this information to enable you to display or
share this information with other players if these functions are available in
your region. |
Necessary to perform our contract with you to provide calling card
features. |
|
Data Subject Request Information: country/region, name,
user email address, screenshot of user ID and user nickname, user ID, account
registration date, login method, user nickname of linked social media
account, account UC balance, account BP balance, request details, any other
information necessary to verify your identity, and if the request is made by
a requestor on your behalf, name of requestor, email address of requestor,
requestor's relationship with you, proof of your identity and requestor's
authority |
If a data subject request is submitted, we use this
information to confirm your and, if applicable, the requestor’s identity,
your rights and to process the request. |
Necessary to comply with a legal obligation. |
|
Information generated as part of the Game Services |
||
|
Generated user ID |
We generate this and use this to:
|
Necessary to perform our contract with you to provide and support the
Game. |
|
Battle Information: user data
(such as channel, user ID, nickname) and game data (such as gameplay mode information,
number of kills, movement speed, jump height) |
We generate this and use this to enable you to play the Game. |
Necessary to perform our contract with you to provide and support the
Game. |
|
Game Play Statistics (Level, Score/s), date and time stamps of actions |
We use this information to provide you with feedback and information
about your gameplay and progress. |
Necessary to perform our contract with you to provide the Game. |
|
IP Address |
We use this information to:
|
Necessary to perform our contract with you to provide the Game. |
|
Device ID, Device Information application
version, battery information, WiFi strength, available space, network type,
OS version, OS language, platform, carrier, country code, series ID, Android
ID, OAID, IDFV, device name, device language, screen DPI, system file
information, screen size, device resolution, screen direction, brand,
manufacturer, device model, device hardware information, device statistics
(of cameras, sensors, systems), XWID (if you are a guest user, generated from
your existing device information, Android ID, random UID, and system time),
guest ID, time zone settings, RAM, ROM and CPU information), GPU version
number, baseband information, registration time and login time, IP address, account SDK’s device ID, client version, local
timestamp, VPN
status (i.e. whether you use VPN; this is not stored) |
We use this information:
·
to combat users
registering for multiple accounts and/or account hacking; and ·
to enforce our terms, conditions and policies. If your
account is determined to breach our End User License
Agreement, we may consider
restricting your access to the Game. |
It is in our legitimate interest to ensure the
security of our services, show you content that may be more relevant to you
and your interests, manage registrations, improve our
services and enforce our terms,
conditions and policies. |
|
Routing Information (if you have poor network connection): IP address, network speed |
We use this information to analyse the cause of poor network
connection. |
Necessary to perform our contract with you to allow you to play the
Game. |
|
WiFi SSID (not stored) |
We use this information to download the Game in the background. This
is processed device-side only and is not transferred to us. |
N/A. |
|
Advertising ID and select device information (User ID, Device ID, IP address and engagement data
and search terms) |
If you click on a link that advertises the Game, we store the
Advertising ID for that advertisement and select device information with your
profile. |
It is in our legitimate interests to use this information to monitor
the success of our advertising and marketing programs. |
|
World of Wonder Advertising-related
information: vopenid (WOW user ID), battle information (dtEventTime, ModID, act type,
battle ID, team member list,
round time) |
We use this information to understand your
interests and improve our advertising
and marketing programs. |
It is in our legitimate interests to use this information to improve our advertising and marketing programs. |
|
Chat Data (audio and text, whether inside a battle (e.g. during actual
gameplay) or outside a battle (e.g. in the game lobby)) and chat log data Please note that this data is
not retained by our servers. |
If you enable chat services (audio and/or text) then we will process
such data in order to deliver your messages to other users. |
N/A. |
|
Transaction Records (in-app): payments on Google Play or iOS App Store (user ID,
country, currency, cost, product purchased, IP address, details of
transactions linked to user ID, and device details including IDFV, network
type, network monitoring data, client exports IP, OS version, phone model,
device root status, SDK version, application version) |
We use this information to facilitate your payment and maintain a
record of your transaction history. |
Necessary to perform our contract with you to facilitate your payment
and provide you with details of your transactions. |
|
Transaction Records (third party other than Google
Play or iOS App Store): user information
(name, username, email address, Facebook nickname), device information
(including user ID, package name, API call status, WiFi, storage and network
access permissions, IP address, OS version, type of device, internet
connection), transaction details (time and date, cost, product purchased,
currency, order ID, subscription information (including subscription ID)) and
transaction records (including user ID, time of transaction, country, email,
phone number, purchase history and payment card details) |
We use this information to facilitate your payment and maintain a
record of your transaction history. |
Necessary to perform our contract with you to facilitate your payment
and provide you with details of your transactions. |
|
Transaction Identifiers: user ID, Android ID, operating system, country, IP address, login
channel, information of UC balance change (including date and time stamps of
UC balance change, number of transactions during different periods, number of
top-ups during different periods) |
We use this information in order to detect fraud on the Game Services. |
It is in our legitimate interest to ensure the security of
transactions within our services. |
|
Refund information: transaction ID, delivery status, consumption status, refund
recommendation and user account flag |
We use this information to help inform and improve the refund process
if you request a refund. |
Necessary to perform our contract with you to facilitate your refund
process. |
|
Customer Support Ticket ID & User Communications
with Support or Q&A function: Name (optional), User ID, nickname,
country/region, device information (such as device ID, free space on
device, device model), operating system, login channel ID, application and
Game version, SDK version, battery level, WiFi strength, IP
address, network type and environment, OS version, browser type, Game server,
platform, carrier, country code, language, source of ticket, details of
ticket, number of visits, email address (optional if in-app/in-Game support),
phone number (optional) , social platform
information, ID and nickname (if used to login to
the Game), profile picture, birthday
(day and month), account status (whether an account is suspended and if so,
since when, reason for the suspension and game statistics), registration
time, VIP level, game duration, historical records, items, currency, penalties,
logins, activities, recharge, purchases, in-game friend relationships, game
match data, any question or information that you provide in
communications with our support team or Q&A function, and ticket response
information (including date, URL, number of responses, priority). You also
have the option of providing a photo/screenshot/video recording to illustrate
any errors |
We use this information to: ·
improve our services; ·
respond to your
communications;
|
Necessary to perform our contract with you to provide and support the
Game Services. |
|
Operation Statistics: A record of contact
pages entered, buttons clicked (the Messenger button, the chat button, data
entry form buttons, buttons relating to data subject requests and buttons
relating to ratings), rating information submitted, page view and message
read information |
We use this information to help us understand user behaviour and how
to best support users. |
It is in our legitimate interest to ensure the security of our
services, improve our services and appropriately respond to user
communications. |
|
Safety Observation and Game Operation:
|
We use this information:
If your account is determined to breach our End User License Agreement, we may consider
restricting your access to the Game. |
It is in our legitimate interest to ensure the
security of our services, to maintain a fair gaming environment in the Game,
to manage registrations, to improve our services and to enforce our terms,
conditions and policies. |
|
Illegal Profile Photos: profile pictures from logged in accounts (existing and new users) |
We use this information to detect if your profile picture is related
to the sale of plug-ins or contains pornographic content (e.g. erotic photos)
and change it to a default profile picture if this is the case. |
It is in our legitimate interest to ensure the security of our
services, to maintain a fair gaming environment in the Game and to prevent
the sale of plug-ins or the availability of pornographic content on the
services. |
|
Reported Chat Data: user ID, nickname, chat time, system language, chat sequence number and chat data |
We use this information to identify abuse, harassment, plug-in sales
or other uses of chat in violation of our End User License Agreement, to consider restricting use of chat
function in those cases and, if applicable to your region, to improve the
tools we use to identify such violations. For more information, please refer to the Privacy FAQ for this function. In the case of audio chat, we store the last 30 seconds of the voice
chat on your device. In case of a report or complaint, we process such audio
chat data on our servers for the abovementioned purposes. |
It is in our legitimate interest to ensure the integrity of the Game
and protect users from prohibited conduct. |
|
In-Game
screenshots for player reports from Game-based Events: screenshot
of your in-Game view |
We use this information to facilitate review of your complaints and
reports relating to game-based events (such as in relation to the PUBG Mobile
World of Wonder event), to identify any uses, behaviour or content in
violation of our End User License Agreement or Event rules. You have the option not to upload the screenshot. |
It is in our legitimate interest to ensure the security of our
services and to maintain a fair gaming environment within the Game. |
|
Video
Clips of Suspected Cheating Behaviour:
|
We use this information to review and determine whether users
suspected of cheating have cheated in the Game. |
It is in our legitimate interest to ensure the security of our
services and to maintain a fair gaming environment within the Game. |
|
Complaint
Verification Information:
|
We use this information to: ·
review complaints
and determine whether users suspected of cheating have cheated in the Game;
and ·
notify players who
have filed a report with the outcome of the complaint, if this feature is available in your region. |
It is in our legitimate interest to ensure the security of our
services and to maintain a fair gaming environment within the Game. |
|
Malicious
Content Information:
signatures, nicknames, profile photos, free text, chat histories, email
address and audio self-introduction |
We use this information to detect if you are making available
malicious information (i.e. information relating to sale of plug-ins, UC
tokens, game accounts, information about game power levelling, or
pornographic images) via your signature, nickname, profile photo, audio
self-introduction, free text or chat history within the Game or detect if
your input contains other content that violates local laws or the End User License Agreement and to block content or change it to its
default setting and prompt you to change it subsequently, as applicable. We may contact you via email if we have detected
malicious activity involving your account. |
It is in our legitimate interest to ensure the security of our
services and to ensure all information made available within the Game is
legal. |
|
Cheat Tool Detection Information: device name of any
external devices connected to your mobile phone, resource files and parameter data, cheating
reports, screenshots of the Game from your perspective (which will contain
nicknames and chats of you and your teammates (this information will be
obfuscated), number of kills and game scenes from your perspective), number
of kills, user ID and nickname |
We
use this information to review and determine whether users have cheated in
the Game, for example, if it is apparent you are using any external cheating device
or a tool to remove grass, or reconfigure your speed limit or perspective or
achieve recoilless shooting, in violation of the End User License Agreement. If your account is determined to breach our End User License Agreement, we may consider restricting your access to the
Game. |
It is in our legitimate interest to ensure the
security of our services and to maintain a fair gaming environment within the
Game. |
|
Cheat Behaviour Detection Information: screen
coordinates of your click events (including touch control movements) |
We use this information to detect and
determine whether users have cheated in the Game, for example, if it is
apparent you are inactive during a battle or assisting the enemy team, or are
using an emulator. If your account is determined to breach our End User License Agreement, we may consider restricting your access to the
Game. |
It is in our legitimate interest to
ensure the security of our services and to maintain a fair gaming environment
within the Game. |
|
Real-Time
Game Review Information: user
ID of players suspected of cheating, user ID and player level of reviewer of suspected cheating behaviour,
review results |
We use this information to review and determine whether users
suspected of cheating have cheated in the Game. |
It is in our legitimate interest to ensure the security of our
services and to maintain a fair gaming environment within the Game. |
|
Anti-Plug-in
Information: user data (such as channel, user ID, nickname), game data (such as
gameplay mode information, number of kills,
movement speed, jump height), device information (such as whether the
device is jailbroken, whether security components are disabled), replay video
(generated from game operation records) and reports |
We use this information to review and determine whether users
suspected of cheating have cheated in the Game, analyse and combat cheating. |
It is in our legitimate interest to ensure the
security of our services and to maintain a fair gaming environment within the
Game. |
|
Game
Player Suspension Information (if applicable): user ID, reason and duration of suspension, country/region, nickname, language, login status |
If you are restricted from accessing the
Game and/or using the chat function, we use this information to notify you and to
enforce suspensions and/or reduce the duration of suspensions. |
It is in our legitimate interest to ensure the
security of our services and to maintain a fair gaming environment within the
Game. |
|
Gameplay Management System Information (if you are in certain regions): daily cumulative
gameplay time and daily rest time |
We use this
information to prevent gaming addiction. |
N/A. |
|
Security-Related Information when
transactions are conducted: whether certain billing security features of
the Android SDK (security development kit) are installed on the device, and
if so the version information |
We use this information when transactions are conducted on your
account in order to detect fraudulent payment activity. |
It is in our legitimate interest to ensure the security of
transactions within our services. |
|
Survey Information: personal
information provided by respondents in response to a survey which may
include a respondent’s gender, age or age range, country or region of
residence, income, education, occupation, contact information, nickname, and
any such information which respondent may provide as part of the survey. We will use IMUR Survey services for the Game if you
choose to participate in our surveys. You can also read more in the IMUR
Survey privacy policy available here. |
If you agree to participate in a survey conducted by us, we use this
information to further improve our Game Services and develop new services. |
We collect this information with your consent. |
|
In-Game screenshot information: whether you have taken an in-game screenshot, and
if so the in-game screenshot (which will contain
any content displayed at the time) |
We use this information to facilitate your sharing of any in-game
screenshot on social network. The screenshot is processed device-side only
and is not transferred to us. |
Necessary to perform our contract with you to facilitate sharing of
screenshots. |
|
Highlights Replay Information: Game operation records used to
generate replay videos, nickname, user ID, profile picture and linked social
media service |
We use this
information to provide highlights replay videos
that you can share within the game or on social media if you enable this
function. |
Necessary to perform our contract with you to provide highlights
replay videos that you can share. |
|
Leaderboard Highlights Information: battle replay, nickname, Game server used by
player and ranking |
We use this information to showcase highlights of top players
in-Game. |
It is in our legitimate interest to ensure the integrity of
high-scoring players is supported by appropriate evidence in-Game. |
|
Beta Test Account Authentication Information: login credentials, user ID, account type, Game
level, frequency of use of Game, whether your Game account is bound to a Beta
test account and whether you have cheated in the Game |
If you seek to participate in our Beta test, we use this information
to verify your eligibility. |
Necessary to perform our contract with you to provide the Beta
version. |
|
Group Photo Event Information (if you are in certain regions): the photo you upload, the photo generated, your user ID
and election to share the photo generated |
If you participate in a group photo event, we use this information to
generate a group photo for you, to enable you to save or share the photo on
social network and, if you are eligible, to provide you with rewards. |
Necessary to perform our contract with you to support your
participation in a group photo event. |
|
Sweepstakes Participation Information: name (as shown on passport), email address, user
ID, phone number, mailing address, postal code and country |
If you participate in a sweepstakes event, which may be conducted in-Game, on our Website or
otherwise, we use this information to send you your prize if you win. |
We collect this information with your consent. |
|
Club Information (general): User data (user ID, avatar, rank, country and region,
language, nickname, game title, clan information (including clan ID, name and
role), custom room game data, eligibility tag, gift records, popularity, game
props owned and bookmarked, follows), user-generated content (“UGC”) (picture, text, audio and video
content, likes, comments and other posts you share publicly in the Club or
with other clan members (including custom competition information and clan
announcements) or mirrored to a clan page from your Moments page), social
media links and creator profile and statistics |
We use this information to enable you to create or join clans
(including operating and participating in custom competitions and posting
clan announcements), share or view picture, text or video content, likes,
comments or other posts, tag content, follow creators, give or receive gifts,
display your game title, create or join custom matches or otherwise use or
customize the Club features if available in your region. |
Necessary to perform our contract with you to provide Club services. |
|
Club Information (country and region, province, city, language, friends list) |
We use this information to recommend and display content and clans
that may be of interest to you. |
It is in our legitimate interest to show you content that may be more
relevant to you and your interests. |
|
Club Information (UGC maps):
|
We use this information to facilitate interaction between creators and
players if this feature is
available in your region. |
Necessary to perform our contract with you to provide in-Club UGC map
services. Where in-Game friend information is processed: It is
in our legitimate interest to show other users (your in-Game friends) content
that may be more relevant to or of interest to them. |
|
World of Wonder Creations Interaction Information: gameplay records of World
of Wonder creations, in-Game friends, in-Game avatar |
If you have interacted with World of Wonder creations, we may display
your avatar on the cover of the relevant creator map(s) to your in-Game
friends, to facilitate friend interactions. |
It is in our legitimate interest to show other users (your in-Game
friends) content that may be more relevant to or of interest to them. |
|
World of Wonder (WOW) Incentive Program Information:
User
ID, OpenID, avatar, creation code ID, creation data (including total play count, likes, follows) If
you are eligible to win a cash reward, please refer to “Game-based Event
Information”
above. |
If you are a WOW creator or author, we use this information to provide
the WOW Incentive Program, to evaluate whether you are eligible for (and if
so, the amount of) rewards, and to distribute such rewards (if applicable and
available). |
Necessary to perform our contract with you to provide the WOW
Incentive Program. |
|
Social Media Account Content: Content posted on your social media account, your
social media account nickname and user ID |
We use this information to enable you to showcase content posted on
your social media account in-Game if you choose to bind your social media
account for this purpose. |
Necessary to perform our contract with you to facilitate your display
of your social media account content in-Game. |
|
UGC Information:
|
We use this information to detect whether content shared contains
pornography or other content that violates local laws, community rules or the
End User License Agreement and remove or block
content in such cases. |
It is in our legitimate interest to ensure the integrity of the Game
and protect users from prohibited conduct. |
|
Moments Information: nickname, avatar, replay videos generated with game operation records |
We use this information to enable you to share content with your
friends on your Moments
page. You can also share such content on a clan
page. |
Necessary to perform our contract with you to facilitate your sharing
of content in-Game. |
|
Clan Announcement Information: clan announcement content |
We use this information to detect whether clan announcements contains pornography or other content that violates
local laws, community rules or the End User License Agreement and remove or block content in such cases. |
It is in our legitimate interest to ensure the integrity of the Game
and protect users from prohibited conduct. |
|
Schedule Subscription Information: schedule information |
We use this information to enable you to add event schedule
information to your system calendar and provide calendar reminders. This is
processed device-side only and is not transferred to us. |
N/A. |
|
Club Feature Performance Information: user ID, carrier,
network type, WiFi status, device model, operating system, operating system
version, frame rate, page load time, memory information, exception error,
exception log and stack |
We use this information to optimize the performance of the Club
functions and provide a better user experience. |
It is in our legitimate interest to improve our Club services. |
|
Tournament Qualification Information: country/region and Game data (prop types, wins,
ranking and Game play statistics) |
We use this information to determine if you qualify for a tournament. |
Necessary to perform our contract with you to provide Game
tournaments. |
|
Tournament Invitation Information (free entry): user ID |
We use this information to send you in-Game invitations to free-entry
tournaments, if you qualify for such tournaments. |
Necessary to perform our contract with you to provide Game tournaments. |
|
Tournament Registration Information (if you register for a tournament): name, email
address, country/region, user ID, photo, team name and team photo (as
applicable) |
If you elect to participate in a tournament, we use this information
for registration and verification. |
Necessary to perform our contract with you to support tournament
participation. |
|
E-sports or Community Event Registration Information:
|
If you register for an e-sports event, we use this information to
create a team for you in the tournament, to organise and broadcast the
tournament and to communicate with the team. We use the ID/passport information of players who qualify to attend in
person an e-sports event to verify that you are located within a country in
your nominated Game region and to assist with travel arrangements. |
We collect this information with your consent. |
|
Tournament Recording Information: user ID, nickname,
battle videos, audio and video recordings during matches |
We use this information:
|
It is in our legitimate interest to ensure a fair competition
environment. It is necessary to perform our contract with you if you are included
in marketing and promotional materials. |
|
Tournament Livestream Information:
|
We use this
information in order to livestream (via broadcasting platforms) the
Tournament to allow the public to view the Tournament, to retain a record of
the same (whether on the relevant third party platforms and/or our own
systems), and for service improvement and potential publicity and marketing
purposes. |
Necessary to
perform our contract with you to allow you to participate in the Tournament. |
|
Tournament or Event Prize Delivery Information:
|
If you win a prize in a tournament, we use this information to deliver your prize. |
Necessary to perform our contract with you to deliver your prize. |
|
Event Photos and Videos: photos and videos (including voice and
image) captured of you and your interactions during our events (such as our
community events, conferences, tournaments, and eSports events) |
We use this
information to share the event with the public (whether on a third party
platforms and/or our own systems), and for promotional, publicity and
marketing purposes. |
Necessary to perform our contract with you to allow you to participate
in the event. |
|
Tournament
Player Suspension Information (if applicable): name, Game nickname (including variations) and day
and month of birth |
If you are suspended or from participating in tournaments or e-sports
events for cheating or otherwise violating tournament or e-sports event
rules, we use this information to enforce the suspension. |
It is in our legitimate interest to protect the integrity of the Game
and ensure fair play at tournaments and e-sports events. |
|
Tournament Suspension Notice Information: nickname, reason for
suspension and duration of suspension |
If you are suspended from participating in tournaments or e-sports
events for cheating or otherwise violating tournament or e-sports event
rules, we may publish this information on our Websites or social media
channels. |
It is in our
legitimate interest to protect the integrity of the Game and ensure fair play
at tournaments and e-sports events, including notifying other players if a
participant has been removed for behavior that violates tournament or
e-sports event rules. |
|
FACEIT Information: user ID, match results (including
placement, kills, survival time, damage and other match results) |
If you participate
in Game competitions on the FACEIT service, we will share this information
with FACEIT to facilitate your use of the service. The FACEIT privacy policy available here will apply to the
processing of data by FACEIT. |
Necessary to perform our contract with you to support competition
participation. |
|
Sharing Event Report Information: Game data (prop types, wins, ranking and Game play
statistics). |
If you participate in a sharing event, we use this information to
prepare a report for you. |
We collect this information with your consent. |
|
Season and Anniversary Review Information: combat data and game stats (such as weapon hit
rate, weapon use time, cumulative eliminations, hits data, daily records,
number of airdrops opened, most used weapons and props) and team data (stats
on performance with friends, such as
number of rescues, number of top 10 rankings, winning percentage and
number of joint wins, games and rescues, most teamed up with friends, friends
with most matches won together, friends with highest and lowest win rate in
team matches) |
We use this information to prepare season reviews and anniversary
reviews for you and to enable you to share such information with other
players if these functions are
available in your region. |
Where used to prepare season reviews and anniversary reviews for you:
Necessary to perform our contract with you to provide season and anniversary
review functions. Where used to prepare season reviews and anniversary reviews for other
players: It is in our legitimate interest provide season and anniversary
review functions to players. |
|
Battle Performance Information: Battle ID, map ID, opening time, player/team user
ID, number of kills by player/team, killing flow, killing count, survival
time, damage amount, heal amount, current round rank, assist count, old
segment level |
For the classic game mode, we use this information to improve resource
distribution in the battlefield. |
It is in our legitimate interest to improve our services. |
|
Battle Matchmaking Information: User ID, country/region, language, in-game friend
list, transaction records, communications volume, engagement with the Game
(login frequency and online time), number of friends, task completion record,
reporting (by other users) and punishment record, Game
data (prop types, wins, ranking, level, achievements, and Game play
statistics (including Game history and performance)), in-Game purchase
history (time and date, cost, product purchased) (if applicable) |
We use this information to understand your performance (such as skill
levels) and preferences, to provide a better user experience if this feature
is available in your region. |
It is in our legitimate interest to improve our services. |
|
Offline Team Invitation Information: User ID,
in-Game friends list, Facebook name, Facebook ID, Facebook profile picture,
whether you log in via Facebook, your Facebook friends list, whether a
Messenger friend is also a player of the Game who logs in via Facebook, and
if so, such friend’s user ID, Facebook name, Facebook ID and Facebook profile
picture |
We use this information so that you can invite
friends to team up even when they are offline. |
Necessary to perform our contract with you to
connect you with your friends. |
|
Account Security Alert Information: Email, user ID,
suspicious account activity, player confirmation of account security |
If you choose to bind your account with your email address, we
will send an account security alert to your email address if we detect any
suspicious activity. |
It is in our legitimate interest to ensure the security of our
services and your account. |
|
Account Recovery Information: Social media account
information/email address/telephone number linked to your account, device ID,
device brand and model, region where you were when you logged in, login time,
network connection method, game mode, recharge time, public channel message
time and competition registration data (registered/unregistered) |
If you need to recover your account, we will use this information
to ask you questions to verify your identity. |
It is in our legitimate interest to ensure the security of our
services and your account. |
|
Captcha Data: browser language, page URL, status of web worker (if any),
verification attempts, browser features, user-agent, screen resolution, page
and screen dimensions, page referrer, OS, CPU, canvas value, font, property
hash, browser resize, WebGL info, GPU, time zone, plugins, color depth, web
driver, character set, device and cursor position, load time, time stamp,
login cookie, javascript settings, battery status, IP address, storage and DB
status, DoNotTrack status, AdBlock status, domain |
We use this information to verify that you
are a real person, in order to protect the security and integrity of the
Game. |
It is in our legitimate interest to ensure
that access and login attempts for the Game are genuine. |
|
UGC Map Information: user ID, nickname, map ID, map name, map description, map, number of
times map was favourited, played and adapted, number of times map was voted
on and user ID of voter (for map-related events and competitions), map
instructions (placement and game rules) |
We use this information
to allow you to share user-generated maps, to participate in and submit your
user-generated maps to our related events or competitions (if applicable),
and to provide you with player feedback, if these functions are available in
your region. Other players can play, copy and modify the maps. |
Necessary to perform our
contract with you to provide UGC map functions. |
|
UGC Map Review Information: user ID, nickname, map ID, map name, map description, map, number of
times map was favourited, number of times map was played, map scene recording |
We use this information to detect whether content
shared contains pornography or other content that violates local laws,
community rules or the End User License Agreement and remove or block content in such cases. |
It is in our legitimate interest to ensure the
integrity of the Game and protect users from prohibited conduct. |
|
UGC Map Creator Certification Information: social media account profile (social
media account ID, number of followers of social media account, social media
homepage link), questionnaire responses, email address or Discord ID |
We use this information to conduct creator
certification and to manage creators if these functions are available in your
region. |
Necessary to perform our contract with you
to provide UGC map functions. |
|
Friend Interaction Information: nicknames and
interaction information such as time of becoming friends in-Game, number of
times you invited each other to form teams, number of times you formed teams
with each other, number of times you rescued each other |
We use this information to facilitate friend
interactions and to operate and manage team activities and achievement
progress. |
Necessary to perform our contract with you to connect you with your
friends. |
|
Friend Interaction Push Notification Information: nickname and friend
interactions |
We use this information to send you push
notifications about friend interactions. |
We collect this information with your consent. |
|
Ptopia Design Project (“PDP”) Information: login information (user
ID, status token, username, profile picture, initial login channel ID,
channel information), personal homepage information (user ID, nickname,
avatar, title of work(s), update time of work(s), number of thumbs up, number
of comments, number of views, number of events participated), application
information (user ID, nickname, email address, telephone number (optional),
type of work(s)), cookie information (language, client type, source, area ID),
content information (user ID, profile picture, nickname, content of work(s),
title of work(s), cover art, type of work(s), description of work(s)), like
and comment information (nickname, profile picture, content and time),
participation information (list of events participated, name and time of
event), voting information and reward information |
We use
this information to enable you to view or participate in activities on the
PDP platform. |
Necessary to perform our contract with you to provide PDP services. |
|
PDP Moderation Information: user ID,
nickname, profile picture, content of work(s), title of work(s), cover art,
description of work(s), comments |
We use this information to detect whether content shared or comments
posted contain pornography or other content that violates local laws,
community rules or the End User License Agreement and remove or block content in such cases. |
It is in our legitimate interest to ensure the integrity of the Game
and protect users from prohibited conduct. |
|
Photo Wall Information: in-Game photos or photos from your device
photo album that you upload to your in-Game photo wall, user ID |
We use this information to enable you to upload in-Game photos or
photos from your device to display them on your in-Game photo wall, if you
choose to do so. |
Necessary to perform our contract with you to facilitate the display
of your photos in-Game. |
|
If we determine your uploaded photo violates local laws, community
rules or the End User License Agreement, we will remove or block your uploaded content in such cases. |
It is in our legitimate interest to ensure the integrity of the Game
and protect users from prohibited conduct. |
|
|
Information you provide to
us (either directly or through a third party) |
||
|
Social Connect Information (if you choose to log in via your social media
account with these networks):
|
We use this information to enable you to log in to your account for,
and access, the Game Services. |
Necessary to perform our contract with you to provide the Game
Services. |
|
Email Login Information: email
address, user ID |
We use this information to enable you to log in to
your account for, and access, the Game Services by email address (once
verified by way of a verification code sent to you). |
Necessary to perform our contract with you to provide the Game
Services. |
|
User Registration Information: name, region
location (as selected by you), area ID, email address |
We use this information to enable you to register as
a player on the eSports Website and to participate in eSports events. We will
send you a verification code to verify your email address. |
Necessary to perform our contract with you to provide the Game
Services. |
|
Account Binding Information: user ID,
profile picture, nickname, ranking information |
We use this information to bind your Game account as
part of player registration on the eSports Website. |
Necessary to perform our contract with you to provide the Game
Services. |
|
Team Information: user ID,
profile picture, nickname, email address, age, place of residence, character
ID, ranking information/ screenshot with ranking information, team name,
Discord ID, Discord username (for captain only), region, team slogan, team
role (captain or member), uploaded images or screenshots (as applicable) |
We use this information to enable you to form, view
or join teams and to participate in eSports events. |
Necessary to perform our contract with you to provide the Game
Services. |
|
eSports Website Event Registration
Information: profile picture, nickname, ranking information, team rank, gameplay
statistics |
We use this information to enable you to participate
in eSports events. |
Necessary to perform our contract with you to provide the Game
Services. |
|
Customer Support Ticket ID & User Communications
with Support: email address and any
information that you provide in communications with our support team |
We use this information to: ·
respond to your
communications; ·
provide
troubleshooting, such as addressing and remediating technical issues and
bugs; and ·
improve our
services. |
Necessary to perform our contract with you to provide and support the
Game Services. |
|
Information generated as
part of the Game Services |
||
|
Chat Data: user ID, chat message (stored locally on
your device and processed momentarily by our servers) |
We facilitate your chat communications with your team members. |
Necessary to perform our contract with you to provide the Game
Services where you seek to use chat services. |
|
Notification Information: user ID |
We use this information to send you notifications about announcements,
updates or information relating to the eSports Website services. |
Necessary to perform our contract with you to provide the Game
Services. |
|
Website Events (if
available in your region) |
||
|
Information you
provide to us (either directly or through a third party) |
||
|
Social Connect Information (if you choose to log in via your social media
account with these networks):
|
We use this information to enable you to create and log in to your
account for the Website event services. |
Necessary to perform our contract with you to provide the Website
event services. |
|
Email Login Information: user ID,
email address |
We use this information to enable you to create and
log in to your account for the Website event services by email address (once
verified by way of a verification code sent to you). |
Necessary to perform our contract with you to provide the Website
event services. |
|
Event Registration Information: user ID,
in-Game screenshot with user ID, Discord ID, region
location (manually selected by you), telephone number |
We use this information to enable you to register
for a Website event. Discord ID and telephone number are used to provide information about
the Website event as well as Q&A and customer services (on Discord and if
applicable, WhatsApp). In-Game screenshot with Game player ID is also used
to detect if you are making available malicious
information within the Game Services. For more information, please refer to “Malicious Content
Information” above for this
function. |
Necessary to perform our contract with you to provide the Website
event services. |
|
Lucky Draw Winner Information: hashed nickname |
If you participate in a Website event and win, we use this information to announce your win. |
It is in our legitimate interest to announce lucky draw results. |
|
Prize Delivery
Information (Physical Prize): name, telephone number, address with zip code |
If you win a physical prize at a Website event, we use this information to deliver your prize. |
Necessary to perform our contract with you to deliver your prize. |
|
Prize Delivery Information (In-Game Prize): user ID |
If you win an in-Game prize at a Website event, we use this information to deliver your prize. |
Necessary to perform our contract with you to deliver your prize. |
We may collect other personal information from you from time to time for specific reasons
(such as a promotion or contest in your country). When this happens, we
will provide more information on any specific changes to the way we process
that personal information that might differ to this privacy policy prior to
collecting or processing any additional information. In some cases, that
information may be shared with us with your consent – and if that is the case,
we will provide you with further information on how we process that information
and your rights.
3. How We Store and Disclose Your Personal Information
Our corporate group operates around the
world. Pursuant to our contract with you to
provide you with the Game Services, your personal information will be processed
on servers that may not be located where you live. Your information can
be accessed from outside of where you live by our support, engineering and
other teams around the world, including Singapore, the People’s Republic of
China, Egypt, Turkiye, Malaysia, Brazil and Mexico. No matter where our servers are located, we take
appropriate measures to safeguard your rights in accordance with this privacy
policy. Our servers for the Game Services are located in:
·
Russia
(in the case of users located in Russia only); and
·
Singapore.
For completeness, we may also have servers located in
other jurisdictions which process or store data for the Game Services that is
not personal information, such as servers in the United States for storage of
certain game data that does not contain your personal information.
If you choose to provide us with your telephone number
and/or email to receive information on game updates via SMS and/or email and in
order for us to send you SMS verification codes, your information will be
stored in Singapore. Additionally, the SMS service providers located in Hong
Kong SAR, Singapore as well as your local carrier will have access to
the data, including to the SMS Sending Records.
Only where necessary will we disclose your personal information
to third parties. Situations where this occur are:
·
Third
parties that provide services in support
of the Game Services, including providers of cloud and network
services that process or back up information identified in this privacy policy
on their servers for the purpose of providing the Game Services and
other providers for the purpose of sharing of in-game photos on WeChat, Facebook, VKontakte, QQ, Twitter, Google Play, Game Center or
LINE (as applicable), for the purpose of user
authentication, for the purpose of processing customer support ticket IDs and
support communication or Q&As, for the purpose of analysing crashes and
improving service performance, for the purpose of providing marketing and
advertisements and monitoring the success of our marketing and advertising programs,
for the purpose of providing you with updates and information regarding the
Game Services, for the purpose of providing translations, for the purpose of
detecting whether user-generated content and chats violate applicable laws, our
terms or community rules, for the purpose of organizing and promoting
tournaments and e-sports events, for the purpose of distributing digital
prizes, for the purpose of delivering physical prizes, for the purpose of
facilitating your participation in Game competitions or eSports events on
third-party services, for the purpose of payment processing services (including
security and fraud detection) and for the purpose of informing and improving the refund process if you request a refund. All companies providing services for us are prohibited
from retaining, using, or disclosing your personal information for any purpose
other than providing us with their services in support of the Game Services.
o enforce our terms and conditions and other agreements,
including investigation of any potential violation thereof;
o detect, prevent or otherwise address security, fraud or
technical issues; or
o protect the rights, property or safety of us, our
users, a third party or the public as required or permitted by law (exchanging
information with other companies and organisations for the purposes of fraud
protection and credit risk reduction).
4. The Security of Your Personal Information
We are committed to maintaining the
privacy and integrity of your personal information no matter where it is
stored. We have information security and access policies that limit access to
our systems and technology, and we protect data through the use of
technological protection measures such as encryption.
Unfortunately, the transmission of
information via the internet is not completely secure. Although we will
implement and maintain reasonable measures to protect your personal
information, we cannot guarantee the security of the information transmitted through
the Game Services or
otherwise via the Internet; any transmission is at your own risk.
|
Personal Information |
Retention Policy |
|
Game |
|
|
Nickname, Hashed Nickname, User ID, IP Address |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. |
|
Social Connect Information:
·
QQ |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days or
as otherwise required by law. |
|
Social Connect Information: ·
VKontakte ·
Twitter ·
Facebook ·
Google Play ·
Game Center ·
LINE |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 3 months after the Game is shut down, before it is deleted. |
|
Gender |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Gender Information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 3 months after the Game is shut down, before it is deleted. |
|
Date of Birth |
Not stored. This is processed device-side only and is not transferred
to us. |
|
Email address (for verification of parental or guardian consent) Region Location (manually selected by you) Game Play Statistics (Level, Heroes, Score/s), date and time stamps of
actions |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Location
information (province and city manually selected by you) and nickname Birthday feature
information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 90 days after the Game is shut down, before it is deleted. |
|
Battle Information |
Not stored. This is processed during the battle only. |
|
Game-based Event Information (digital prizes) |
Stored for 1 year after the conclusion of the event. |
|
Game-based Event Information (physical prizes) |
Stored for 1 year after the conclusion of the event. |
|
Game-based Event Information (cash prizes) |
Stored for 6 months after the conclusion of the event. |
|
Calling Card Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Data Subject Request Information |
Stored for 3 years. |
|
Gameplay Management System Information |
Cached for the day and deleted every 24 hours |
|
Chat Communications (Audio message) – whether inside a battle (e.g.
during actual gameplay) or outside a battle (e.g. in game lobby) |
We do not store this information. |
|
Chat Communications (Text) – outside and inside a battle |
Stored for 7 days on our servers and deleted automatically upon expiry
of such period. |
|
Device ID, Device Information, registration time and login time |
Device ID, Device Information (except VPN
status), registration time and login time: Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days (or
within 7 days of user request for account or data deletion in respect of
XID). Where you do not request for account deletion, such data will be
retained for 3 months after the Game is shut down, before it is deleted. VPN status: Not stored. This is processed
device-side only and is not transferred to us. |
|
Routing Information |
Stored for 1 year. |
|
WiFi SSID |
Not stored. This is processed device-side only and is not transferred
to us. |
|
Friends List (WeChat, Facebook, QQ, VKontakte, Twitter) |
Stored for the duration of each session on the Game and deleted within
1 hour after you log out. |
|
Friends List (manually added by you) |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Advertising ID and select device information (User ID, Device ID, IP
address and engagement data and search terms) World of Wonder Advertising-related
information |
Stored for the lifetime of your use of the Game (i.e. until account deletion
in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for up to 1 year after the Game is shut down, before it is deleted. |
|
Transaction Records (in-app) Transaction Records (third party other than Google Play or iOS App
Store) |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then for the duration of any
retention periods for which such data must be retained in order to comply
with our legal obligations. |
|
Transaction Identifiers Refund Information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 3 months after the Game is shut down, before it is deleted. |
|
Customer Support Ticket ID & User Communications with Support or
Q&A function |
Support data is deleted within 30 days of a lawful request from you
for the erasure of such data (see the Erasure section of this privacy
policy). |
|
Operation Statistics |
Stored for 90 days. Upon a deletion request, we will delete the data within 30 days. |
|
Security and Operation Information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. |
|
Security-Related Information (if you are using the Game on a PC) |
We generally retain this data for no longer than 90 days with the
exceptions listed below. · File sample collection and
memory sample collection related to confirmed malicious activities: up
to 10 years; · In-game process information
and system information: up to 10 years; · Security
authentication: up to 5 years. Upon a deletion request, we will delete the data within 30 days except
where they relate to confirmed malicious activities. |
|
Illegal profile photos |
If no violation is found, stored for 1 day. If any violation is found, stored for the shorter of 3 years or until
account deletion in accordance with your request and then deleted within 30
days. |
|
Reported chat data |
For End User License Agreement violations: user ID and documented chat are stored for 180 days if
any violation is found. For improving tools used to identify violations: Documented chat
(which is anonymized) is stored for the lifetime of your use of the Game
(i.e. until account or data deletion in accordance with your request) and
then deleted within 30 days. Where you do not request for deletion, such data
is retained for 3 months after the Game is shut down, before it is deleted. In the case of audio chat: Real-time voice chat data will only be stored on your device and not
be stored on our servers, unless a report or complaint is made, in which case
the last 30 seconds of the data are stored on our servers to enable us to
review the complaint or report. This data will be deleted as soon as the
review is complete and in any event within 30 days. For improving tools used to identify violations for voice chat data and to facilitates the review
of penalties for violations and misjudgments: If any violation is found, the voice file (which is marked, anonymized
and encrypted) is stored for 1 year. |
|
In-Game
screenshots for player reports from Game-based Events |
If you choose not to upload the screenshot, not stored by us. If you upload the screenshot and no violation is found, stored for 90
days. If you upload the screenshot and no violation is found, stored until
the Game is shut down unless you request to delete your Game account or data,
upon which such data will be deleted within 30 days. |
|
Video clips of suspected cheating
behaviour |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. |
|
Complaint
Verification Information |
If no violation is found, stored for 90 days. Upon a deletion request,
we delete the data within 15 business days. If any violation is found, stored for the lifetime of your use of the
Game (i.e. until account or data deletion in accordance with your request)
and then deleted within 15 business days. Where you do not request for
deletion, such data is retained for 30 days after the Game is shut down,
before it is deleted. |
|
Malicious Content Information |
Free text is only
processed momentarily and not stored. Other information
is stored for the lifetime of your use of the Game
(i.e. until account deletion in accordance with your request) and then
deleted within 30 days. |
|
Cheat tool detection information |
For device name
of any external devices connected to your mobile phone: stored for up to 7 days. For other information: If no violation is found, stored for up to 7 days. If any violation is found, stored for the lifetime of your use of the
Game (i.e. until account deletion in accordance with your request and then
deleted within 30 days). In some cases, such data may be stored for a shorter
period (e.g., 3 years after collection). |
|
Cheat Behaviour Detection
Information |
Where you do not request for account or data
deletion, such data will be retained for 1 year after the Game is shut down,
before it is deleted. Stored for the lifetime of your use of the Game unless
you request to delete your Game account or data, upon which such data will be
deleted within 30 days. Where you do not request for account or data
deletion, such data will be retained for 3 months after the Game is shut
down, before it is deleted. |
|
Real-Time Game Review Information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 1 year after the Game is shut down, before it is deleted. |
|
Anti-Plug-in Information |
Not stored if not reported or suspected of cheating. If reported or if cheating is suspected: Replay video is stored for 120 days. Other information is stored for 30 days. |
|
Game Player Suspension Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Survey Information |
Stored for up to 1 year. |
|
In-Game screenshot information |
Not stored. This is processed device-side only and is not transferred
to us. |
|
Highlights Replay Information |
For any highlights replay video you share: Highlights Replay Information is stored for the lifetime of your use
of the Game (i.e. until account deletion in accordance with your request) and
then deleted within 30 days. Where you do not request for account deletion, such data will be
retained for 90 days after the Game is shut down, before it is deleted. For videos not shared: Not stored. Please note that any highlights published outside of the Game (for
example, to social media), may remain available via such services even if
deleted from the Game. |
|
Leaderboard Highlights Information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30
days. |
|
Beta Test Account Authentication Information |
Stored for the lifetime of your use of the Beta test (i.e. until
account deletion in accordance with your request) and then deleted within 30
days. Where you do not request for account deletion, such data will be
retained for 2 months, before it is deleted. |
|
Group Photo Event Information |
For any photo you share: The photo you upload and the photo generated are
processed device-side only and are not transferred to us. Your user ID and election to share the photo
generated are stored for the lifetime of your use of the Game
(i.e. until account deletion in accordance with your request) and then
deleted within 30 days. For photos not shared: No information is stored. This is processed device-side only and is
not transferred to us. |
|
Sweepstakes Participation Information |
Stored for up to 1 year after the conclusion of the sweepstakes event. |
|
Club Information (general) Club Information (country and region, province, city, language,
friends list) Club Information (UGC maps) |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any picture, text, audio and video content,
comments and other posts you share any time. |
|
World of Wonder Creations Interaction
Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
World of Wonder (WOW) Incentive Program
Information |
Stored for 2 years, unless you request to delete your Game account or
data, upon which such data will be deleted within 30 days. |
|
Social Media Account Content |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any picture, text and video content you share any
time. |
|
UGC Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any picture, text, audio and video content you
share any time. In relation to text or picture content sent by users in-Game: If no
violation is found, stored for 60 days. |
|
Moments Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any video content you share any time. |
|
Clan Announcement Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. You can also delete any announcement you post any time. |
|
Schedule Subscription Information |
Not stored. This is processed device-side only and is not transferred
to us. |
|
Club Feature Performance Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Tournament Qualification Information |
Stored for up to 6 months from the time of collection. |
|
Tournament Invitation Information (free entry) |
Stored for up to 6 months from the time of collection. |
|
Tournament Registration Information |
Stored for 3 months from the time of collection. |
|
E-sports Event Registration Information |
Stored for up to 3 months from the conclusion of the
tournament. |
|
Tournament Recording Information |
Where this is used to validate Game user and to investigate any
allegation of cheating, stored for up to 6 months from the conclusion of the
tournament. Where this is used in marketing and promotional materials, stored for
the duration of the marketing campaign. |
|
Tournament Livestream Information |
We may enable the livestream videos to remain available on the
platform that broadcasts the livestream in perpetuity. We may also separately retain the video recordings of the livestreams
in perpetuity. |
|
Tournament or Event Prize Delivery Information |
Stored for up to 6 months from the conclusion of the tournament. |
|
Event Photos and Videos |
We may post event photos and videos to our platforms our third party
social media platforms in perpetuity. We may also separately retain the photos and videos in perpetuity. |
|
Tournament Player Suspension
Information |
Stored for the duration of the suspension. |
|
Tournament Suspension Notice
Information |
Stored for the duration of the suspension |
|
FACEIT Information |
Stored for the lifetime of your use of the Game (i.e. until account
deletion in accordance with your request) and then deleted within 30 days or
as otherwise required by law. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Sharing Event Report Information |
Stored for 1 year after the conclusion of the event. |
|
Season and Anniversary Review Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Battle Performance Information (other than number of kills) |
Deleted when the battle is over. |
|
Battle Performance Information (number of kills) |
Stored for 21 days. |
|
Battle Matchmaking Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Telephone number or email for the purposes of binding your account
with your telephone number and/or email address and/or associated social
media account, for providing game updates, for providing game promotion
emails where applicable to your region, and for providing manual customer
service Two-factor authentication information SMS Sending Records |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. SMS Sending Records will be stored by the SMS service provider for up
to three months after which they will be deleted automatically. |
|
Telephone number and User ID (if you elect to be featured on
leaderboards) SMS Sending Records |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. SMS Sending Records will be stored by the SMS service provider for up
to three months after which they will be deleted automatically. |
|
Offline Team Invitation Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Account Security
Alert Information Account Recovery
Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Captcha Data |
Stored for 30 days
from the date of collection and then deleted. |
|
UGC Map Information UGC Map Review
Information UGC Map Creator
Certification Information |
Map scene recording: Stored for 14 days. Other information: Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. We may also host events whereby map creators may submit their, and
other users can vote on, UGC maps. For such events, we also store UGC Map
Information for 6 months. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Friend Interaction
Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Friend Interaction
Push Notification Information |
Stored for up to 3 months. |
|
PDP Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
one month. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
PDP Moderation Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
one month. Where you do not request for account or data deletion, such data will
be retained for 3 months after the Game is shut down, before it is deleted. |
|
Photo Wall Information |
Stored for the lifetime of your use of the Game unless you request to
delete your Game account or data, upon which such data will be deleted within
30 days. You can also at any time delete any photo you share. Stored for 30 days for content moderation. |
|
eSports Website |
|
|
Social Connect Information Email Login Information User Registration Information Account Binding Information Notification Information eSports Website Event Registration Information Customer Support Ticket ID & User Communications with Support |
Where you do not request for account or data
deletion, such data will be retained for 3 months after the Game is shut
down, before it is deleted. If you participate
in eSports events hosted on third party platforms or services, please also
refer to the relevant third party’s privacy policy and retention policy. |
|
Team Information |
Stored until 30
days from dissolution of team. |
|
Chat Data |
We do not store
this on our servers. This is only processed momentarily by us to deliver your
chat communications. |
|
Website Events |
|
|
Social Connect Information Email Login Information Event Registration
Information Lucky Draw Winner
Information Prize Delivery Information
(Physical Prize) Prize Delivery Information
(In-Game Prize) |
Stored until 30 days after
the conclusion of the event. |
If we are required to retain your
information beyond the retention periods set out above, for example to comply
with applicable laws, we will store it separately from other types of personal
information.
Some jurisdictions’ laws grant specific rights to
users of the Game Services, which are set out in this section.
This section entitled “Your Rights”
applies to users that are located in the Relevant Jurisdictions. If you are
located in a territory outside a Relevant Jurisdiction, please refer to the
Supplemental Jurisdiction-Specific Terms for an overview of your rights and how
these can be exercised.
The sub-sections entitled “Access”,
“Correction”, and “Erasure” also apply to users that are located in Canada,
India, Russia and the
Kingdom of Saudi Arabia.
The sub-sections entitled “Email Opt-Out”
and “SMS Opt-Out” also apply to users that are located in Canada, Egypt, India,
Malaysia, Mexico, Russia, Singapore, the United Arab Emirates and the United
States.
You have certain rights in relation to the
personal information we hold about you, depending on where you are located.
Some of these only apply in certain circumstances (as set out in more detail
below). We must respond to a request by you to exercise those rights without
undue delay and at least within one month (though this may be extended by a
further two months in certain circumstances). To exercise any of your rights,
please submit your request at https://www.pubgmobile.com/datasubject.
Access
You have the right to access personal
information we hold about you, inquire how
we use it, and who we disclose it to by contacting us at https://www.pubgmobile.com/datasubject. You can access the personal information you have
made available as part of your account by logging into your account. If you
believe we hold any other personal information about you, please contact us at https://www.pubgmobile.com/datasubject.
Portability
You have the right to receive a copy of
certain personal information we process about you by contacting us at https://www.pubgmobile.com/datasubject. This comprises any personal information we process
on the basis of your consent or pursuant to our contract with you, as described
above in the section “How We Use Your Personal Information”. You have the right to receive this personal
information in a structured, commonly used and machine-readable format. You
also have the right to request that we transfer it to another party, with
certain exceptions. We will provide further information to you about this if
you make such a request.
Correction
You have the right to correct any of your
personal information we hold that is inaccurate. You can correct the personal information we hold about you by logging
into your account and/or by contacting us at https://www.pubgmobile.com/datasubject. If you believe we hold any other personal
information about you and that information is inaccurate, please contact us
at https://www.pubgmobile.com/datasubject.
Erasure
You can delete your account, or remove certain
personal information, by logging into your account and/or by contacting us at
https://www.pubgmobile.com/datasubject. If there is any other personal information you
believe we process that you would like us to erase, please contact us at https://www.pubgmobile.com/datasubject.
We may need to retain personal information if there
are valid grounds under data protection laws for us to do so (for example, for
the defence of legal claims or freedom of expression) but we will let you know
if that is the case. Where you have requested that we erase personal
information that has been made available publicly on the Game
Services and there are grounds for erasure, we will use reasonable steps to try
to tell others who are displaying the personal information or providing links
to the personal information to erase it too.
Restriction of Processing to Storage Only
You have a right to require us to stop
processing the personal information we hold about you other than for storage
purposes in certain circumstances. Please note, however, that if we stop
processing the personal information, we may use it again if there are valid
grounds under data protection laws for us to do so (for example, for the
defence of legal claims or for another’s protection). As above, where we agree
to stop processing the personal information, we will try to tell any third
party to whom we have disclosed the relevant personal information so that they
can stop processing it too.
You have the right to object to our processing of your
personal information. We will consider your request in other circumstances as
detailed below by contacting us at https://www.pubgmobile.com/datasubject.
To the extent provided by applicable laws and
regulations, you may withdraw any consent you previously provided to us for
certain processing activities by contacting us at https://www.pubgmobile.com/datasubject. Where consent is required to
process your personal information, if you do not consent to the processing or
if you withdraw your consent we may not be able to deliver the expected
service.
Email
Opt-out
You may choose to stop receiving game update emails or, where applicable to your region, game
promotion emails, from us by following the
unsubscribe instructions included in these emails or you can contact us at service@pubgmobile.com.
SMS
Opt-out
You may opt out of receiving game update
marketing or advertising text messages by contacting us at service@pubgmobile.com, and sharing the phone number that you would like to
opt out. For text messages, you also may be able to text “STOP” in response to
a text message that you receive.
Announcements
We may from time to time send you announcements
when we consider it necessary to do so (for example, when we temporarily
suspend access to the Game Services for maintenance, or security, privacy or
administrative-related communications). You may not opt-out of these
service-related announcements, which are not promotional in nature.
We welcome questions, comments and
requests regarding this privacy policy. Please address them to dpo@proximabeta.com.
In the event that you wish to make a
complaint about how we process your personal information, please contact us in
the first instance at dpo@proximabeta.com and we will endeavour to deal with your request
as soon as possible. This is without prejudice to your right to launch a claim
with the data protection authority in the region in which you live or work
where you consider we have infringed data protection laws.
If you have an unresolved privacy or data
use concern that we have not addressed satisfactorily, please contact our
U.S.-based third-party dispute resolution provider (free of charge) at
https://feedback-form.truste.com/watchdog/request.
If we make any material changes to this
privacy policy, we will post the updated policy here and notify you in
accordance with relevant legal requirements.
9. Language
Except as otherwise prescribed by law, in the
event of any discrepancy or inconsistency between the English version and local
language version of this privacy policy, the English version shall prevail.
SUPPLEMENTAL
JURISDICTION-SPECIFIC TERMS
Some jurisdictions’
laws contain additional terms for users of the Game Services, which are set out
in this section.
If you are a user located in one of the
jurisdictions below, the terms set out below under the name of your
jurisdiction apply to you in
addition to the terms set out in our privacy policy above.
Algeria
By
using the Game Services, you
give us your consent for the collection, storage, treatment and use of your
personal information, and transfer of your personal information to a third
party (such as local cloud providers to back up your data or our affiliates
around the world to help us deliver the Game Services) located in Singapore (as
described in the Privacy Policy) where it is
manually and electronically treated.
Argentina
Your rights
If you are dissatisfied with
our response to your request for access to, correction, or erasure of your
personal information or your privacy complaint in respect of your personal
information, you may contact the Agency for Access to Public Information at:
Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone:
+5411 3988-3968 or email: datospersonales@aaip.gob.ar).
Data transfers
While we take reasonable steps
to ensure that third party recipients of your personal information comply with
privacy laws that are similar to those of your jurisdiction, by providing us
your personal information and by using the Game Services, you consent to the
transfer of your personal information to a jurisdiction where privacy laws may
not offer the same level of protection as the laws that may apply in Argentina.
Australia
Overseas Recipients
We take reasonable steps to ensure
that third party recipients of your personal information located outside
Australia handle your personal information in a manner that is consistent with
Australian privacy laws. However, you acknowledge that we do not control, or
accept liability for, the acts and omissions of these third party recipients.
Access
You have the right to access personal
information we hold about you, how we use it, and who we share it with. You can
access the personal information you have made available as part of your account
by logging into your account. If you believe we hold any other personal
information about you, please contact us at dpo@proximabeta.com.
Correction
You have the
right to correct any of your personal information we hold that is inaccurate.
You can access the personal information we hold about you by logging into your
account. If you believe we hold any other personal information about you and
that information is inaccurate, please contact us at dpo@proximabeta.com.
Children
If you are under the age of 18, you
undertake that you have the consent of your parent or legal guardian to
register an account on and use the Game Services.
Transacting Anonymously
Where
practicable, we will give you the option of not identifying yourself or using a
pseudonym when registering an account on or using the Game Services. You
acknowledge that if you do not provide us with your personal information, we
may be unable to provide you with access to certain features or sections of the
Game Services, including social media integration and in-Game purchases.
Your Rights
If you are
dissatisfied with our response to your request for access to, or correction of,
your personal information or your privacy complaint in respect of your personal
information, you may contact the Office of the Australian Information
Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).
Data Transfers
While we
take reasonable steps to ensure that third party recipients of your personal
information comply with privacy laws that are similar to those of your
jurisdiction, you acknowledge and agree that we cannot control the actions of
third party recipients and so cannot guarantee that they will comply with those
privacy laws.
Bangladesh
Agreement
By accepting this Privacy
Policy, you
expressly state that you authorise us to collect, use, store, and process your
personal data, including disclosing to third parties, to the extent provided by
this Privacy
Policy. By
clicking the button to proceed, you consent to the cross-border transfer of
your information to any country where we have databases or affiliates and, in
particular, to Singapore,
the People’s Republic of China, Egypt, Turkiye, Malaysia, Brazil and Mexico.
Age Restriction
In order to use the Game Services, you represent that you are
at least 18 years old and, therefore, legally capable of entering into binding
contracts.
Brazil
This section applies to users located in
Brazil:
Consent Revocation
Whenever we use your personal information
based on your consent, you may revoke the consent that you have previously
given for the collection, use and disclosure of your personal information,
subject to contractual or legal limitations. To revoke such consent, you may
terminate your account or you can contact us at https://www.pubgmobile.com/datasubject. This may affect our provision of the Game Services
to you.
Parental and Guardian Consent
If you are under the age of 18, you should
not use the Game Services for any purpose without first obtaining
parental/guardian agreement to this privacy policy (both for themselves and on
your behalf). We do not knowingly collect personal information from any
children under the age of 18 without such consent. Please contact our Data
Protection Officer if you believe we have any personal information from any
children under the age of 18 without such parental/guardian consent – we will
promptly investigate (and remove) such personal information.
BY ACCEPTING THIS PRIVACY POLICY, YOU
EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR
PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES AND TRANSFERRING
TO COUNTRIES OTHER THAN BRAZIL, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.
United States
For purposes of this section, “personal information” and “sensitive
personal information” have the meanings given in the California Consumer
Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020)
(“CCPA”), and respectively include the terms “personal data” and “sensitive
data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act
Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah
Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act
(“VCDPA”), (collectively, “US State
Laws”). The terms do not include
information excluded from the scope of US State Laws.
Collection and Disclosure of Personal
Information
Over the
past 12 months, we have collected and disclosed for a business purpose the
following categories of personal information from or about you or your device:
We collect and disclose your personal information,
including sensitive personal information, for the following purposes:
For additional information
about what each type of personal information is used for, see this chart in the main portion of the privacy policy.
We disclose each of the categories of personal
information that we collect as described in Section 3 (How We Store and Disclose
Your Personal Information).
In the
past 12 months, we have not sold or shared personal information of California
residents within the meaning of “sold” and “share” in the CCPA, and we have no
knowledge of any sale or sharing of personal information of users under 16
years of age.
In
addition, we do not use or disclose sensitive personal information for purposes
other than to perform the services reasonably expected by an average consumer
who requests those services or as otherwise permitted by US State Laws. In the
past 12 months, we may have collected the following types of sensitive personal
information about you:
· Your chat
data
Retention
of Your Personal Information
The retention period varies
among the different categories of data collected. For detailed information
about the retention period for any specific category of data, see this
chart in the main portion of the Privacy Policy.
Rights under US State Laws:
Depending on where you live, you may have
some or all of the rights listed below in relation to information that we have
collected about you. However, these rights are not absolute, and in certain
cases, we may decline your request as permitted by law.
How to Exercise Your Rights
First, you may wish to log into your account and
manage your data from there. Depending
on where you live, you may also exercise your rights, if any, regarding other
data by contacting us at https://www.pubgmobile.com/datasubject. We may take steps to verify your identity
before complying with your request to protect your privacy and security, and
may decline your request if we are unable to verify your identity. To verify
your identity, we may need you to provide the Data Subject Request Information set out in the
section “How We Use Your Personal Information”.
Depending on where you live, you may exercise these rights yourself or you may also designate an
authorized agent to make these requests on your behalf. In order for us to
process the request, you must provide the authorized agent with signed written
permission. We reserve the request to
require the agent to verify their own identity and to confirm directly with you
that you have provided the authorized agent permission to submit the request.
In addition, where
applicable, we will provide you with more information about our appeal process.
When you submit a request or launch an appeal, we will limit our collection of
your information to only what is necessary to securely fulfil your request or
process your appeal. We will not require you or your authorized agent to pay a
fee for the verification of your request or appeal.
Questions
If you have questions or
concerns regarding this Privacy Policy, please contact us at dpo@proximabeta.com.
Canada
If you are located in Canada and wish to obtain
written information about our policies and practices with respect to our
service providers located outside Canada, you may contact us at dpo@proximabeta.com. Our
privacy experts who monitor this email address are also able to answer any
questions users may have about the collection, use, disclosure or storage of
personal information by our service providers.
Where we use service providers who might have access
to your personal information, we require them to have privacy and security
standards that are comparable to ours. We use contracts and other measures with
our service providers to maintain the confidentiality and security of your
personal information and to prevent it from being used for any purpose other
than as provided in this privacy policy.
Colombia
How We Use Your Personal Information
From the entry
into force of this Privacy Policy, at the time of the collection of your
personal data, we will request your prior authorization, by informing you about
the specific purposes of the processing of your personal data for which such
consent is obtained under the Privacy Policy.
Your authorization
may be expressed (i) by writing, (ii) orally or (iii) through unequivocal
conducts that allow us to reasonably conclude that your authorization was
granted, such as the act of accepting the Privacy Policy. We may keep evidence
of said authorizations, while respecting the principles of confidentiality and
privacy of information.
Your Rights
As a data subject you have certain rights, including (i) to
access, update and rectify your personal data; (ii) to request a copy of the
consent you have given us; (iii) to be informed about how we have processed
your personal data; (iv) to file claims before your country’s data protection
authority; (v) to revoke the consent you have given us to process your personal
data, unless the processing is based on compelling legitimate grounds or is
needed for legal reasons; (vi) to ask for the suppression of your personal data
(right to erasure); and (vii) to freely access your information.
You can contact us if you want to exercise any of these
rights through our contact information in the section ‘Contact &
Complaints’ of this Privacy Policy.
Proceedings For The Exercise Of
Your Rights
Queries (rights to access): You can file queries regarding
the processing of your personal data by us.
Claims (right to correction and erasure): You have the right
to file claims in relation to the processing of your personal data by clearly
describing the facts that give rise to your claim.
Egypt
This privacy policy is provided in Arabic for users
located in Egypt. In case of dispute, the Arabic version of this privacy policy
shall prevail.
By clicking the button to proceed or by proceeding
with the sign up process, you acknowledge that you have read, understood, and
consented to this privacy policy. If you do not consent to this privacy policy,
you must not use the Game Services.
You are acknowledging your consent to the processing,
storage, and cross-border transfer of your personal data. The cross border
transfer may be to any country in which we have databases or affiliates, in
particular Singapore, the People’s Republic of China, Egypt,
Turkiye, Malaysia, Brazil and Mexico.
You also acknowledge your consent to receiving
marketing messages from us, whether through e-mails or pop-ups or other such
means.
If you are a new user, you have seven days to inform
us of any objection you may have to this privacy policy.
As an Egyptian data subject, you have certain rights
under the Egyptian Personal Data Protection Law.
France
Your Rights
Instructions
for the processing of your personal data after your death
You have the right to provide us with general or specific instructions for the retention,
deletion, and communication of your personal data after your death.
The specific instructions are only valid for the processing activities
mentioned therein and the processing of these instructions is subject to your
specific consent.
You may amend or revoke your instructions at any time.
You may designate a person responsible for the implementation of your
instructions. This person will be informed of your instructions in the event of
your death, and be entitled to request their implementation from us. In the
absence of designation or, unless otherwise provided for, in the event of the
death of the designated person, their heirs will have the right to be informed
of your instructions and to request their implementation from us.
When you
wish to make such instructions, please contact us at dpo@proximabeta.com.
Hong Kong
As a Hong Kong data subject you have legal
rights in relation to the personal information we hold about you (to the extent
permitted under applicable laws and regulations).
You are entitled to make a subject access
request to receive a copy of the data we process about you, a data correction
request as well as a right to reject to the use of your personal data for
direct marketing purposes. A fee may be chargeable by us for complying with a
data access request.
India
Age Restrictions
Parental consent is required for children
under the age of 18 years to use our services.
Sensitive Personal
Information
Sensitive Personal Information under local
law includes passwords, financial information (such as bank account, credit
card, debit card or other payment instrument details), biometric data, physical
or mental health, sex life or sexual orientation, and/or medical records or
history, but does not include information available in the public domain, or
provided under Indian laws, including the Right to Information Act, 2005.
Sharing Of Your
Sensitive Personal Information
Where we permit any third parties to collect and use
Sensitive Personal Information, we shall use reasonable measures to ensure that
the third parties do not further disclose the Sensitive Personal Information to
the extent required by applicable laws.
Withdrawal Of Consent
To the extent provided by applicable laws and
regulations, you may withdraw any consent you previously provided to us for
certain processing activities by contacting us at https://www.pubgmobile.com/datasubject.
Where consent is required to process your personal information, if you do not
consent to the processing or if you withdraw your consent, we may not be able
to deliver the expected service.
Indonesia
Consent
By
accepting and consenting to this privacy policy, you agree that we may collect,
use and share your personal information in accordance with this privacy policy,
as revised from time to time. If you do not agree to this privacy policy, you
must not access or use our services and we have the right to not provide you
with access to our services.
Parental and Guardian
Consent
If you
are under the age of 21, you undertake that you have the consent of your parent
or legal guardian to register an account on the Game and use the Game Services.
Data Subject Rights
You
have the right to access your personal information stored in our Game from time
to time in accordance with applicable data privacy laws and regulations in
Indonesia.
Data
Breach
In the
event we fail to maintain the confidentiality of your personal information in
the Game Services, we will notify you through the contact information provided
by you or via the Game Services, to the extent required by local laws and
regulations.
Data Retention
We
will retain your personal information in line with legal requirements.
Data Accuracy and Third
Party Consent
You are responsible for making
sure that any personal details which you provide to us are accurate and
current. In order to confirm the accuracy of the information, we may also
verify the information provided to us, at any time. You hereby represent that
you have secured all necessary consent(s) before providing us with any other
person’s personal information (for example, for referral promotions), in which
case we will always assume that you have already obtained prior consent, and as
such, you will be responsible for any claims whatsoever from any party arising
as a result of the absence of such consent(s).
Kazakhstan
If you are
under the age of 18, you must obtain your parent’s or legal guardian’s consent
to register an account on and use the Game Services.
By
accepting this Privacy Policy, you consent to the collection, use, disclosure,
transfer, export (to the extent permitted by applicable laws), sharing and
storage of your personal information as described in this Privacy Policy. The
transfer of your personal information to third parties, which may include the
cross-border transfer of your information to any country where we have
databases or affiliates and, in particular, to Singapore, the People’s Republic
of China, Egypt,
Turkiye, Malaysia, Brazil and Mexico.
Your Rights
· Right of access: You have the right to request access to and obtain a copy of the
personal information we have process about you or that is being processed on
behalf of us. We reserve the right to impose a fee for providing access to your
personal information in the amounts as permitted under law.
When handling a data access request, we are permitted to request for
certain information to verify the identity of the requester to ensure that
he/she is the person legally entitled to make the data access request.
·
Right to correction: You may request
for the correction of your personal information or delete such personal
information if it is impossible to correct it. When handling a data correction
request, we are permitted to request for certain information to verify the
identity of the requester to ensure that he/she is the person legally entitled
to make the data correction request.
·
Right to blocking
/ de-blocking: You have the right to
request the blocking of personal information related you, if you become aware
of a violation regarding the collection and processing your data. If the
violation has not been proved, you may request to de-block your data.
·
Right to deletion: You have the right to request deletion of your personal data if the
collection and processing of your data has been conducted in violation of
Kazakh laws.
·
Processing of your
personal information in public sources of personal data:
You may request to limit or provide your consent on the processing of your
personal information in public sources of personal data.
Kingdom of Saudi Arabia
You
consent to the collection, use, disclosure, transfer, export (to the extent
permitted by applicable laws) and storage of your personal information as
described in this privacy policy,
Kuwait
You
represent that you are at least 21 years old, or 18 years old and have obtained
parental/guardian consent and, therefore, legally capable of contracting under
the applicable laws and regulations in Kuwait.
By
accepting this Privacy Policy, you expressly state that you authorise us to
collect, use, store, and process your personal data and to disclose this data
to third parties whether inside or outside of Kuwait, in line with the
provisions of this Privacy Policy.
Macau SAR
You
have the right not to provide your personal information. However, as a result,
we may not be able to provide the Game Services to you. As a Macau SAR data
subject you have legal rights in relation to your personal information (to the
extent permitted under applicable laws and regulations). You are entitled to
make a subject access request to request a copy of the data we process about
you, to make a data correction request, and have the right to oppose the use of
your personal information for marketing or any other form of commercial
prospecting, or on any grounds of personal nature. A fee may be chargeable by
us for complying with a data access request.
Malaysia
Parental and Guardian Consent
If you are under the age of
18, please do not use the Game Services.
In the event you are
agreeing to this privacy policy in order for a minor to access and use the Game
Services, you hereby consent to the provision of personal information of the
minor to be processed in accordance with this privacy policy and you personally
accept and agree to be bound by the terms in this privacy policy. Further, you
hereby agree to take responsibility for the actions of such minor, and that
minor’s compliance with this privacy policy.
Your Rights
Right of access: You have the right to
request access to and obtain a copy of your personal information that we have
collected and is being processed by or on behalf of us. We reserve the right to
impose a fee for providing access to your personal information in the amounts
as permitted under law.
When handling a data access
request, we are permitted to request for certain information to verify the
identity of the requestor to ensure that he/she is the person legally entitled
to make the data access request.
Right of correction: You may request for the
correction of your personal information. When handling a data correction
request, we are permitted to request for certain information to verify the
identity of the requestor to ensure that he/she is the person legally entitled
to make the data correction request.
Right to limit processing of your personal
information: You may request to limit the processing of your personal information by
using the contact details provided above. However this may affect our provision
of the Game Services to you.
Contact
To protect your personal
information and handle complaints relating to your personal information, we
have appointed the following department responsible for managing and protecting
your personal information.
Mexico
Age Restrictions
Please
do not use the Game Services unless you are 18 years old or you have obtained
parental/guardian agreement to this Privacy Policy (both for themselves and on
your behalf).
Types of Personal Information We Use
For
clarification purposes, in section "The Types of Personal Information We Use” and
section “How We Use Your Personal Information” you
can find full details about the personal data we use. Therefore, we are
providing you with complete information about the personal data we use, in
terms of the Federal Law on Protection of Personal Data held by Private Parties
and other applicable regulations.
Purposes of Processing
Some
of the purposes of processing stated above are for voluntary purposes,
including to show you personalised recommendations. We may also use your
personal data for the voluntary purpose of sending information to your email or
SMS that we may consider relevant to you. You may object to the processing of
your personal data for voluntary purposes as stated in the section “Your Rights”
below.
Please
be informed that we may also use your personal data to comply with legal
obligations or requests from competent authorities, assert or defend our rights
before the competent authorities / courts, respond to requests you send us in
relation to your personal data and carry out the transfer of personal data
detailed in section “How We
Store and Disclose Your Personal Information”.
Data Transfer Consent
In
general, we do not require your consent to carry out the transfers detailed in
section “How We
Store and Disclose Your Personal Information”.
However, we require your consent to transfer your personal data to a third
party that acquires all or substantially all of us or our business.
By
using the Game Services and providing us with your personal data, you agree to
the data transfers detailed above that require your consent. You may exercise
your rights in connection with your personal data as stated in the section “Your Rights”
below.
Your Rights
The
sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”,
“Restriction of Processing to Storage Only”, which include limitation to the
use and disclosure of your personal data, and “Email Opt-Out” and “SMS Opt-Out”
included in Section “Your Rights” above
also apply to users that are located in Mexico.
You also have the right to revoke the consent that you have provided us
to process your personal data.
To
exercise any of your rights, contact our Data Protection Officer at dpo@proximabeta.com.
To
know more about your rights, as well as the applicable means, procedures and
requirements to exercise any of your rights, please contact our Data Protection
Officer at dpo@proximabeta.com.
Cookies
Through
the use of cookies, we collect certain information related to your browsing and
device, some of which may be considered personal data (detailed in our Cookies
policy here). You
may be able to refuse or disable cookies by adjusting your browser settings.
Because each browser is different, you should consult the instructions provided
by your browser. If you choose to refuse, disable, or delete cookies, some of
the functionalities of the Game Services may no longer be available to you. For
more information about our use of cookies and how to disable them, please visit
our Cookies policy here.
Morocco
The protection of your privacy is an
important principle for us. We collect information for purposes strictly
necessary for the proper use of the Game Services.
By accepting these conditions of
use, you explicitly accept that your personal data may be subject to processing
by the Game Services.
Kindly note:
·
the identity of the Data
Controller is Proxima
Beta Pte. Limited, email: dpo@proximabeta.com.
·
the purposes of the
processing for which the data is intended are set out in the table in the
section “How We Use Your Personal Information”.
·
recipients or categories of
recipients are set out in the second paragraph of the section “How We Store and Disclose
Your Personal Information”.
·
whether the answer to the
questions is compulsory or optional, as well as the possible consequences of a
lack of answer: please refer to the section “How We Use Your Personal Information” and the section “Your Rights” (sub-paragraph
“Objection”).
New
Zealand
This section applies to users
located in New Zealand:
Overseas Recipients
We take reasonable steps to ensure
that third party recipients of your personal information located outside New
Zealand handle your personal information in a manner that is consistent with
New Zealand privacy laws. However, you acknowledge that we do not control, or
accept liability for, the acts and omissions of these third party recipients.
Access
You have the right to access
personal information we hold about you, how we use it, and who we share it
with. You can access the personal information you have made available as part
of your account by logging into your account. If you believe we hold any other
personal information about you, please contact us at dpo@proximabeta.com.
Correction
You have the right to request the
correction of any of your personal information we hold that is inaccurate. You
can access the personal information we hold about you by logging into your
account. If you believe we hold any other personal information about you and
that information is inaccurate, please contact us at dpo@proximabeta.com.
Children
If you are under the age of 16,
you undertake that you have the consent of your parent or legal guardian to
register an account on and use the Game Services.
Your Rights
If you are dissatisfied with our
response to your request for access to, or correction of, your personal
information or your privacy complaint in respect of your personal information,
you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).
Data Transfers
While we take reasonable steps to
ensure that third party recipients of your personal information comply with
privacy laws that are similar to those of your jurisdiction, you acknowledge
and agree that we cannot control the actions of third party recipients and so
cannot guarantee that they will comply with those privacy laws.
Peru
You may exercise rights related to the protection
of personal information by requesting access to your personal information or
the correction, deletion or suspension of processing of your personal
information, etc. pursuant to applicable laws such as the Personal Data
Protection Law (the “Law”).
You may also exercise these rights through your
legal guardian or someone who has been authorised by you to exercise the right.
However, in this case, you must submit a power of attorney to us in accordance
with the Law.
Upon your request, we will take necessary measures
without delay in accordance with applicable laws such as the Law.
You can also withdraw your consent or demand a
suspension of the personal information processing at any time.
If you consider that your request has not been met
you may file a claim with the Peruvian National Authority of Personal Data
Protection.
Contact
To protect your personal information and handle
complaints relating to your personal information, we have appointed the
following department responsible for managing and protecting your personal
information.
Philippines
Minimum Age
You must be at least 18 years of age to be able to use the Game
Services.
Your Rights
You are entitled to the following rights:
Consent
By consenting to this Privacy Policy, you consent to us:
· collecting
and processing your personal information as described in the section “How We
Use Your Personal Information” above;
· sharing your
personal information with third parties, companies within our corporate group, and a
third party that acquires all or substantially all of us or our business, as
described in this Privacy Policy and for the purposes stated herein; and
· transferring
or storing your personal information in destinations outside the Philippines as
described in the section “How We Store and Disclose
Your Personal Information” above.
Qatar
If you are using the Game Services in Qatar, you
consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal
Data, as may amended from time to time) to the processing of your information
in accordance with this Privacy Policy.
Russia
If you are using the Game Services in Russia, this section
“Russia” applies to you. By using the Game Services:
The sub-sections “Access”, “Correction”, “Erasure”, “Restriction
of Processing to Storage Only”, “Objection”, “Email Opt-Out” and “SMS Opt-Out” of the section “Your Rights”
above apply to users in the Russian Federation.
We will notify you of any material changes and may request you to
acknowledge such changes. Unless we require your acknowledgment, you shall be
deemed to have agreed to the changes if you continue using the Game Services
after the notification.
As regards the representative for Russia, you can contact us at dpo@proximabeta.com.
Please include the word “Russia” in the subject line of your email.
Separate
consent for using certain data
For the purposes of the operation of the Service, as part of its
activities, we do not distribute (publicly disclose) personal data without the
appropriate consent of the data subject and in compliance with the requirements
of Article 10.1 of Russian Federal Law No. 152-FZ dated 27 July 2006 “On
Personal Data” (as amended).
By using the Game Services you also consent to the sharing of your
personal information with certain third parties for the purposes set out under
section “How We
Store and Disclose Your Personal Information”.
You determine, in your discretion, the terms of disclosure to the
general public of your personal data, by choosing to use certain features of
the Game Services and by choosing the appropriate privacy settings in respect
of your personal information in the Game Services.
We process your personal information subject to the terms of this
Privacy Policy and your chosen features and settings.
This consent is granted for as long as you use the Game Services.
The consent may be withdrawn by you (and you may set any restrictions on
processing of your relevant personal information) at any time by contacting us
(dpo@proximabeta.com): please include the word “Russia” in the subject line of your
email.
Serbia
Our designated local representative in Serbia is Karanovic &
Partners for the purposes of compliance with the Law on Personal Data
Protection, and can be contacted at local.representative@karanovicpartners.com.
Please include the word “Serbia” in the subject line of your email.
Singapore
By clicking the button to proceed, you consent to the cross-border
transfer of your information to any country where we have databases or
affiliates and, in particular, the People’s Republic of China, Egypt,
Turkiye, Malaysia, Brazil and Mexico.
Access
You have the right to access your personal
information, how we use it, and who we share it with. You can access the
personal information you have made available as part of your account by logging
into your account. If you believe we hold any other personal information about
you, please contact us at https://www.pubgmobile.com/datasubject.
Correction
You have the right to correct any of your
personal information that is inaccurate. You can access the personal
information we hold about you by logging into your account. If you believe we
hold any other personal information about you and that information is
inaccurate, please contact https://www.pubgmobile.com/datasubject.
Our designated data protection officer for the purposes of compliance with
the Personal Data Protection Act 2012 can be contacted at dpo@proximabeta.com.
South Africa
You have the right to lodge a complaint with the Information Regulator
(South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s
physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark,
Braamfontein, Johannesburg, South Africa.
Sri Lanka
By clicking
the button to proceed, you consent to the terms and conditions of the Privacy
Policy and permit the collection, use and disclosure of your personal
information. However, if you are under the age of 18, you undertake that you
have the consent of your parent or legal guardian to register an account on and
use the Game Services.
Where you
request to withdraw consent, refrain from further processing of data, erase,
rectify or complete your personal information, we will provide you with our
response to the request within 21 working days.
Thailand
By accepting this privacy policy, you acknowledge that you have read,
understood, and agree to this privacy policy. If you do not agree with this
privacy policy, you must not use the Game
Services.
If you are under the age of 20, you undertake that you have obtained your
parent or legal guardian’s consent to register an account on and use the Game
Services.
To the extent provided for by the Thai
Personal Data Protection Act (PDPA), you may:
· withdraw your consent to the processing of
your personal data (only where the legal basis for our processing is consent);
however, please note that where consent is required to process your personal
data, we may not be able to deliver the expected service without it;
· request us to provide you access to, make any
correction to, cease any automated processing or profiling (if applicable),
discontinue, restrict the use or provision of and/or erase your personal data;
· request us to provide you or a third party
with your personal data which is stored by us in a machine readable format;
and/or
· lodge a complaint to a relevant authority.
Where you wish to make such requests, please contact us at https://www.pubgmobile.com/datasubject.
The contact details
of our designated local representative in Thailand for the purposes of
compliance with the PDPA is as set
out in the section “Contact Information”
and can be contacted via
email. Please include the word “Thailand” in the subject line of your email.
Türkiye
Our Data Controller Representative in
Türkiye for the purpose of compliance with Turkish Law on Personal Data
Protection Law (“DPL”) and its
secondary regulations, Özdağıstanli Ekici Avukatlık Ortaklığı, can be contacted
at turkeydatarep_proximabeta@iptech-legal.com. Please include the word “Türkiye” in the subject
line of your email.
You have legal rights, which are set forth
in Article 11 of the DPL, in relation to the personal information data we hold
about you. As a Turkish data subject, you may have the right to apply to the
data controller and (to the extent permitted under applicable laws and
regulations):
In accordance with Article 9 of the DPL, your personal
data may be transferred abroad as follows:
|
Identity of the overseas recipient |
Location of the recipient (or as otherwise stated in the recipient’s
privacy policy) |
Purposes of use of Personal Information by the recipient |
Items of Personal Information to be provided |
|
|
Aceville Pte. Ltd. |
Singapore |
Storage of personal information |
All personal information as set out in the section “How We Use Your
Personal Information” |
|
|
Hong Kong and Singapore |
User authentication |
Captcha Data as set out in the section “How We Use Your
Personal Information” |
||
|
Sending of SMS verification codes |
Telephone number, country code and SMS content |
|||
|
Functional
Software, Inc. d/b/a Sentry |
United States and other countries where Sentry or its affiliates,
future subsidiaries or service providers maintain facilities |
Crash analysis |
User ID, device model, OS version, exception stack and exception log,
network type, memory information |
|
|
Google LLC |
Any country in which Google or its sub-processors maintain facilities |
Storage of personal information |
Tournament Player Suspension Information as set out
in the section “How
We Use Your Personal Information” |
|
|
|
|
Speech-to-text function (all languages except Chinese and English) |
User-generated content (audio converted to text) |
|
|
CEC
GienTech Technology (Shenzhen) Co., Ltd. |
People’s Republic of China |
Identify abuse, harassment, plug-in sales or other uses of chat in
violation of our End User License Agreement; assist us in improving tools we use to identify such violations |
Reported chat data (including the anonymised voice file) |
|
|
GameStars
Inc. |
United States |
Provide online platform for eSports events |
eSports
Website Event Registration Information |
|
|
Shenzhen
Baby Elephant Entertainment Culture Entertainment Co., Ltd |
People’s Republic of China |
Process payments for cash prizes
|
Game-based Event
Information (cash prizes) |
|
Ukraine
By accepting this Privacy Policy, you expressly authorize us to collect,
use, store, and process your personal data, including disclosing to third
parties and transferring to countries or regions other than Ukraine, to the
extent and for the purposes provided in this Privacy Policy.
United Arab Emirates
You consent to the collection, use, disclosure, transfer, export
(to the extent permitted by applicable laws) and storage of your personal
information, as described in the privacy policy.
We may voluntarily report a cyber-security incident where it
constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The
incident can be reported to the relevant authorities for the purpose of
investigations. Please note that voluntary reporting of a cyber-security
incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness
organisation that provides a process for logging incidents and advising on
known cyber security threats in the UAE.
PRIVACY FAQ
IN-GAME CHAT SAFETY
FUNCTION
1. Introduction
We take
your data privacy and security very seriously. We take steps to ensure that
your content is stored and processed by us in a transparent way and using
secure and reliable technology.
We
understand that your trust is something we earn. As part of that process, we
work to keep you informed of our data privacy policy and measures, as they may
change over time.
This
FAQ explains some common questions on a feature for certain regions concerning
chat of PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE (“Game”), particularly for those users
and prospective users who have questions about how we meet our requirements
under data protection laws and other applicable regulations concerning data
privacy.
For
further information regarding our data privacy practices and this FAQ:
(a)
Please review the PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE Privacy Policy
– which sets out how we collect, store and process your personal data to
provide you with the Game, and the End User
License Agreement for
PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE.
(b)
Please contact our privacy team via email at dpo@proximabeta.com should
you have any further questions.
2. What is the in-game chat safety function?
To
ensure the Game provides a safe platform for users of the Game, we have
introduced an in-Game chat safety function (“Safety Feature”) in certain regions. The Safety Feature helps us to
improve your experience of the Game by flagging users who use chat function in
violation of our End User
License Agreement. For
countries where the law requires that we have a legal basis for
processing certain data, we operate the Safety Feature in our legitimate
interests to ensure the safety and integrity of our Game. The Safety Feature
works to identify, for example, unsolicited commercial communications, including
plug-in sales and advertising, spam, harmful communication, exploits, bullying,
harassment, threats of violence or conduct which is hateful, harassing,
abusive, racially or ethnically offensive, defamatory, humiliating,
threatening, profane or similarly objectionable (“Prohibited Conduct”).
3. What are the consequences for users who engage in
Prohibited Conduct?
All
users are required to comply with our End User
License Agreement, and
you should familiarize yourself with your obligations as part of our gaming
community. In order to ensure a safe gaming environment for our users we may
take action against users who violate the End User
License Agreement or otherwise engage in
Prohibited Conduct, which may include limiting use of those features that have
been abused.
4. How can I use the Safety Feature and how does it work?
When
you observe a user engaging in Prohibited Conduct, you can press the “Report”
button on the screen if this feature is available in your region. This will
record a short snippet of the chat, and for voice chat, convert it into text at
the same time or store the last 30 seconds of the voice chat on our servers.
The chat data may be automatically translated if needed. The chat data will be
reviewed for Prohibited Conduct and, in certain regions, for improvement of the
tools we use to identify violations.
5. What if I think I have been implicated by mistake?
We have
implemented safeguards to ensure any consequences are appropriate and
proportionate to the relevant Prohibited Conduct and the frequency with which
such Prohibited Conduct has occurred.
We will
notify you if you have been muted or restricted from sending chats as a result
of your breach of the End User
License Agreement. If
you think your use of the chat functions was restricted by mistake, please
contact us at service@pubgmobile.com
to request a review.
6. Do you warn users before taking action?
We may
not issue a warning before restricting your use of the chat functions but we
will notify you if restrictions are made.
7. Do you store chats and where do you store them?
The
Safety Feature is designed to protect your privacy. Documented chat and the
clip (for voice chat) is not stored, except where the information provides
evidence of Prohibited Conduct by a user. In these cases we store the
documented chat as evidence, and in certain regions we
also store the documented chat and voice file in anonymized form for
improvement of the tools we use to identify violations, on our servers in Singapore
and subsequently automatically delete it in accordance with our Privacy Policy.
8. Do you disclose chats to any third parties?
We do
not disclose any chats of any user to any third party, except where necessary
for the review and translation process and to assist us in improving our
anti-cheating tools, or in exceptional circumstances, such as where we believe
we are legally required to (for example, if we are subject to a court order for
disclosure), or where we need to do so in order to enforce or protect your
rights, our rights or the rights of other users. Please consult our Privacy Policy
for further details.
9. Can I object to your processing of my chats?
Yes. If
you are a resident of a relevant country as noted in our Privacy Policy,
you may have the right to object to, and seek restriction of, our processing of
your chats for this purpose. To exercise your right, please contact us at dpo@proximabeta.com
and please consult the Privacy Policy
for further information.
We will
consider several factors when assessing an objection, including: our users'
reasonable expectations; the benefits and risks to you, us, or other users as a
result of our implementation of the Safety Feature; and other available means
to achieve the same purpose the Safety Feature achieves that may be less
invasive and do not require disproportional effort. Unless the processing is
based on our compelling legitimate grounds or is needed for legal reasons, your
objection will be upheld and we will cease processing your information.
10. Is the Safety Feature secure and how do you comply
with data protection laws?
We have
a comprehensive global privacy program directed at protecting your personal
data. You can read about how we process and protect personal data in our Privacy Policy.
We also use a variety of security technologies and procedures for the purpose
of preventing loss, misuse, unauthorized access or disclosure of your
information.
11. How do you respond to law enforcement requests for
chat information?
We may,
from time to time, receive law enforcement requests to disclose your chat
information (and its translation) to regulators, courts or law enforcement
bodies. When we receive these requests, we take reasonable steps to query them
and establish whether or not we are legally required to respond to them. When
we are legally required to respond to such a request, we will take measures to
safeguard your legal rights and your personal data.