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Privacy Policy

Last Updated Date: 31 January 2023

1. Introduction

1.1. This Privacy Notice describes how Refract Technologies Pte Ltd and its group companies (collectively described as “Refract”, “we”, “us”, “our”) collect, use, disclose, process and share (collectively, “process”) information about you.

1.2. This Privacy Notice applies to all of our services, including our websites and online platforms, and applications and games (whether used or played on our websites, on mobile devices, PCs, game consoles, or other gaming platforms). It also applies to our marketing and advertising activities on all platforms and other services that we may provide to you from time to time. In this Privacy Notice, we refer to our applications, games, websites, online platforms, and other services collectively as our “Services”.

2. Acceptance of this Privacy Notice

2.1. By downloading, accessing, and/or using our Services, you acknowledge the terms of this Privacy Notice.

2.2. In certain jurisdictions, we will require your consent to process your personal data. Where consent is required, by accepting our Privacy Notice as part of the sign-up process for an account with us, you consent to us processing your personal data for the purposes set out in this Privacy Notice. By registering for an account with us, providing your information to us through the Services, or otherwise accessing or using any of our Services, you understand and acknowledge that we may process your personal information in accordance with this Privacy Notice.

2.3. If you do not agree to the terms of this Privacy Notice or do not want this Privacy Notice to apply to you, please do not use the Services or communicate with us via the Services.

2.4. If we change our Privacy Notice, we will make the amended Privacy Notice available on our website. We reserve the right to amend this Privacy Notice at any time without notice.

3. Data We Collect

3.1. The types of personal data we collect will depend on the Services you use, and the requirements of applicable law. We generally collect the types of data described below.

Data that you provide us with:

3.1.1.identity and profile information (such as name, photo and data or birth);
3.1.2. contact information (such as your delivery address, email address and phone numbers);
3.1.3. user name or tag and password;
3.1.4. account and transaction data (such as information on your purchases and delivery or billing information); User information and content (such as your messages and other information you submit when you use our Services such as chat logs and user support tickets); and
3.1.5. data you provide in connection with surveys, promotions, competitions and other events.

Data we collect automatically:

3.1.6. data about how and when you use the Services (including gameplay data and progress, and usage information);
3.1.7. your IP address and mobile device identifiers (such as your device or advertising ID);
3.1.8. data about your device (such as device name and operating system, browser type, language, regional or device settings, internet service provider, and mobile carrier);
3.1.9. data we collect with cookies and similar technologies; and
3.1.10. approximate location data (as derived from IP address).

Data we collect from our partners:

We also use third-party partners, such as social networking sites, data analytics providers and advertising networks to supplement information we have about you, and may collect the following from these partners:

3.1.11. data from your linkage of a third-party tool with the Service (such as Steam, LINE, Facebook, WeChat or Kakao);
3.1.12.demographic data (such as to determine the coarse location of your IP address);
3.1.13. data to fight fraud (such as refund abuse in games or click fraud in advertising);
3.1.14. data from platforms that the games run on or data from payment service providers (such as payment verification data);
3.1.15. data for advertising and analytics purposes (such as surveys), so we can provide you a better Service; and
3.1.16. data that you have made available to us from a third party service (such as Steam, LINE, Facebook, WeChat or Kakao) via your privacy settings.

3.2. Where you participate in competitions, contests or other events, we may take photographs, video and audio recordings of the events.

4. Purposes For Which We Process Your Data

4.1. Where you download, access, and/or use our Services or interact with us, we may process your personal data for one or more of the following purposes:

4.1.1. develop and improve our Services, including by carrying out research, planning and statistical analysis;
4.1.2. receive and handle orders, deliver and provide products and services, process payments, and communicate with you about orders, products and services;
4.1.3. operate and administer the use of and access to our Services for you and our other users, and your user account with us;
4.1.4. personalise your experience, including by presenting content or features tailored to your profile, interests or user preferences;
4.1.5. respond to, process and handle your queries, complaints, feedback and requests;
4.1.6. operate, monitor and manage our infrastructure, systems and business operations, and comply with internal policies and procedures;
4.1.7. protect personal safety and the rights, property or safety of others;
4.1.8. organise, administer and manage events or contests;
4.1.9. send you updates on our products and services;
4.1.10. purposes in connection with any claims, actions or proceedings and/or protecting and enforcing our legal rights and obligations, including under our Terms of Service;
4.1.11. meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us; and
4.1.12. any other purpose which we may notify you at the time of obtaining your consent.

4.2. We may use your personal data for marketing purposes, subject to obtaining your consent where this is required under applicable law. This may include sending you information on promotions, offers and rewards.

5. How We Share Your Information

5.1. Subject to the provisions of any applicable law, we may share or disclose your personal data for the above mentioned purposes, with the following recipients:

5.1.1. Other players and users: Our Services may include social features and such features are in particular, a core component of our games. To provide these functions, we may make a limited amount of your personal data available to other users, for example, other users may be able to view your profile data, in-game activities and read the messages you have posted.
5.1.2. Our agents and service providers: We may rely on third-parties to provide business, technical and operational services to us, including for telecommunications, product shipping and delivery, information technology support, payment and billing, customer support, analytics and for fraud prevention. Our agents and service providers may have access to and process your personal data where they perform such services for us.
5.1.3. Our professional advisors: We may need to provide your personal data to our professional advisors such as our auditors and lawyers to receive professional services and advice.
5.1.4. Business partners: We may offer products and services jointly or in cooperation with other companies and organisations. Where you sign-up for, purchase, access or use such products and services, we may provide your personal data to these business partners.
5.1.5. Sponsors: We may make available information about you where you sign-up for events which are sponsored by third-party businesses. This may include your biographic information in order to facilitate your participation in such events, or where you win prizes provided by such sponsors.
5.1.6. Esports organisations: We may provide personal data from your publicly available profile on Maincard to e-sports organisations such as esports competition organisers where they use and/or connect with our platform for the purpose of organising and managing such events.
5.1.7. Game developers and publishers: Where our services require that we connect with or link to games or platforms developed by other game developers or publishers, it may be necessary for us to provide or share a limited amount of your data with such companies. For example, where you use games developed or published by such third-parties in conjunction with the Maincard platform, we may provide a certain amount of your personal data to such developers and publishers.
5.1.8. Advertising and social media partners: Our Services may include features from our advertising and social media partners, such as social media interaction tools, functionalities through application programming interfaces (APIs) or software development kits (SDKs) and in-game advertising. Your personal data may be shared with such partners for the provision of these features.
5.1.9. Judicial, Governmental and Regulatory Authorities: We may need to disclose your personal data to courts, tribunals, enforcement agencies, governmental or regulatory authorities which have jurisdiction over us or our business operations, including where we receive a binding request for such disclosure.

5.2. Where we disclose or share your personal data with other parties, these parties may process your data in accordance with their own privacy policies.

6. International Data Transfers

6.1. Our Service is global by nature and your data may therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Notice. Adequate safeguards that we may use include standard contractual clauses approved by the EU Commission and other lawful safeguards.

7. Your Rights and Options

7.1. The rights available to you in relation to your personal data will depend on the applicable law in your location. These may include:

7.1.1. Access and correction: You may request access to your personal data in our control or possession. If any personal data which we have about you is inaccurate, you may request that we correct the data;
7.1.2. Withdraw your consent: To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time;
7.1.3. Erasure: In certain jurisdictions, you may subject to certain conditions, have the right to request deletion of your personal data; and
7.1.4. Other rights: In certain jurisdictions, you may also have the right to restrict the processing of your personal data, to require that your data be ported to another organisation (i.e. a data portability right), to additional information on our processing of your personal data, to object to automated processing of your data and to complain to a data protection authority.

7.2. We will respond to all requests within a reasonable timeframe. If you wish to exercise any of your data subject rights described above, please use the support options described in “Contact Us”. We will respond to all requests in accordance with applicable laws. To protect your privacy, we may also take additional steps to verify your identity before fulfilling your request, such as by requesting you provide us a purchase receipt or other account information, asking you to link your email address with your game account, or asking you to answer questions regarding your activities on our Services.

8. How do We Protect and Retain Your Data

8.1. Security Safeguards

8.1.1. In order to help ensure a secure and safe player experience, we continuously develop and implement administrative, technical and physical security measures to protect your data from unauthorised access or against loss, misuse or alteration.

8.2. Data Retention

8.2.1. or as needed to provide you the Service. To the extent permitted by applicable law, we may also retain your personal data where necessary for legal or business purposes such as where necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. Children

9.1. Protecting children’s privacy online is very important to us. Generally, our Services are not directed to children under 13 (or other age as required by local law), and the Services do not knowingly collect personal data from children, except as described in the following paragraph.

9.2. For Services that are not directed at children but nonetheless may appeal to them, we take additional steps to limit access to these Services based on the player’s age. For these Services, when a player indicates they are under 13 (or the applicable age in their territory), we will limit their access to certain features, such as social media and chat features, as well as certain types of notification alerts. We also limit the processing of personal data to only what is necessary to support the internal operations of our Services.

9.3. Please note that for some of our Services we may use a higher age limit (such as 16) than described in the above two paragraphs. We do this to provide a safe experience for our users and to protect young users.

9.4. If you are a parent or guardian and wish to review personal data collected from your child, or have that information modified or deleted, you may contact us as described in “Contact Us”. If we become aware that a child has provided us with personal data contrary to the above, we will delete any personal data we have collected, unless we have a legal obligation to keep it, and terminate the child’s account and/or revert them to the underage experience, as applicable.

10. Contact Us

10.1. If you wish to exercise your rights as described in the section “Your Rights and Options”, or have any queries, you may send an email to our Data Protection Officer at dpo@refract.gg. We will process such requests in accordance with this Privacy Policy and our obligations under the Privacy Laws and any other applicable law. However, your withdrawal of consent may mean that we will not be able to continue providing the Services to you and we may need to terminate your existing relationship and/or the contract you have with us.

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