Arena Breakout

Privacy Policy

Last Updated:27October2023

Thankyoufor using our products and services!We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies toArena Breakout(the“Service”)and its official website (the“Website”). If you use any other products or services,please refer to the privacy policy for that particularproduct or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can befoundhere.

For the purpose of data protection laws,the data controller of your personal information in relation to theWebsite and theService isProxima BetaPte.Limited.

SUMMARY

Here is a summary of the information contained in thisPrivacyPolicy.You can find more detailby clicking ‘More Information’.

Welcome toArena Breakout!

ThisPrivacy Policyexplains thewhen,howandwhywhen it comes totheprocessingof your personal informationin connectionwithArena Breakout(the“Service”)and its official website (“Website”),and sets out your choices and rights in relation to that information. Please read it carefully –it will allow youto understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies tothe Websiteandthe Service.If you use any other products or services please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way thisPrivacy Policydescribes, please do not provide your information when requested and stop usingtheWebsite and theService. By using theWebsite andtheService,you areacknowledginghow we processyour personal information as described in thisPrivacy Policy.

For the purpose of data protection laws, the data controller of your personal information in relation to theWebsite andService isProxima BetaPte.Limited(“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be foundhere.You can also reach out to our data protection officer atdpo_uamo@proximabeta.com.

1.                 Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Website. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. For more information about our Cookies policy, click here.

2.               Children

Children must not use theWebsite and theService for any purpose, except where their parent or guardian has provided lawful 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 relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

Other than as provided above, 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 lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, pleasecontact us.

3.               HowWeProcessYourPersonalInformation

This section provides more detail on the types of personal information we collect from you, and why.

For users who live in Brazil, the European Economic Area, Indonesia, Switzerland,Thailand,Türkiye or the United Kingdom, it also identifies the legal basis under which we process your data.

4.               HowWeStore andShareYour Personal Information

Pursuant to our contractwith you, we may transfer data outside of the location in which you are based for the purposes describedin this Privacy Policy.

Our servers for theWebsiteandtheServicearelocated in Singapore.We also have support, engineering and other teams who may support theWebsite andtheService, includingin Singapore andthePeople’s Republic of China.

For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent first or taking into account adequacy assessments.

Only where necessarywill we share your personal information with third parties.Situations where this occur are:

• Thirdpartiesthat provide services in support of theWebsite andService,includingproviders of cloud services that process information identified in this policy on their servers for the purpose of providing theWebsite andService, analytics and ad attribution providers, and providers that carry out surveys.All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for theWebsite andService(i.e., for the purpose(s) described above).
• Companies withinourcorporate groupwho process your personal informationsolely for the purpose of providing theWebsite andService to you. Allsuchgroup companiesmayonly use your personal information in accordance with thisPrivacy Policy.

• Regulators, judicial authoritiesandlaw enforcement agencies.There are circumstances in which wemay belegally required todisclose informationabout you, such as to comply with legal obligationsor processes.In complyingwith the terms of valid legal processes,such as a subpoena, or search warrant,unfortunatelywe may not be able to seekyourconsent to or notify youin advanceofsuchdisclosure.
• Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
  • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such asexchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
• A third party that acquires all or substantially all of us or our business.We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

5.               TheSecurity ofYourPersonalInformation

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 willimplement and maintain reasonable measuresto protect your personalinformation, we cannot guarantee the security of theinformation transmitted through theWebsite andService or otherwise via the Internet; any transmission isat your own risk.

6.               Data Retention

We do not keep your data for longer than is necessaryto fulfil the relevant purpose describedaboveunless we are requiredor permittedto do so under law.If we retain your information beyond the retention periods set outbelow, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

7.               YourRights

Some jurisdictions’ laws grant specific rights to users of theWebsite andService.Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of theserights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, pleasecontact us.

Access

You may have the right to access personal information we hold about you, how we use it, and who we share it with.

Correction

You may have the right to correct personal information we hold that is inaccurate.

Erasure

You may be able to delete your account, or remove certain personal information, by logging into yourServiceaccount.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 Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us atdpo_uamo@proximabeta.com, andwe will consider your request.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend accessto theServicefor maintenance, or security, privacy or administrative-related communications).These are essential system and service-related announcements and you are not able toopt-out of thesenotifications, which are not promotional in nature.

8.               Contact

Please get in touch with us if you have any questions.You can reachus in the first instance at:

Email:dpo_uamo@proximabeta.com

We will endeavour to deal with your request as soon as possible. This is without prejudice toanyrightyou may haveto launch a claim withadata protection authority in theregionin which you live or work where you think we have infringed data protection laws.

9.               Changes

If we make any changes to thisPrivacy Policywe will post the updatedPrivacy Policyhereandnotify you in accordance with relevant legal requirements.

10.           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.
INFORMATION FOR PARENTS

Before your child canparticipate in the Arena Breakout (“Service”), you will need to provide your consent to approve your child’s account set-up and the processing of their personal information.

What personal information doesthe Serviceprocess?

Arena Breakoutis asurvival shooting mobilegame.In the Service,players will roleplay as a soldier to participate in a virtual peacekeeping exercise, and they will enter into a large, open map scene.Playerscan carry different weapons to fight against AI-driven enemies. Players can collect materials, survive and cooperate, and complete challenging tasks in the map scene in the form of single player or team cooperation.

If your child successfully signs up tothe Service, this will result in the collection and sharing of certain personal information:

• username, email address, user ID, profile picture, Open ID and XWID;
• customary device and network information (such as IP address, connection speed, device information and specifications, as well as app- and OS-generated identifiers); and
• other game information.

You can review our Privacy Policy for more details on what personal information we collect and how we use and process the information.

Doesthe Serviceprocess personal information differently for children?

• Yes, your child will not be able to access the in-Service survey and provide survey responses.

Why is my consent required?

Certain jurisdictions require or recommend the consent of a parent or legal guardian before their child can sign up to a game such asArena Breakout, where personal information will be processed. If you do not consent, or withdraw your consent, we will immediately delete any personal information collected up to that point.

What method(s) can I use to verify my child’s account?

In some jurisdictions, including the United States, we ask for date of birth at registration. We will not allow a child to sign-up without first obtaining verifiable consent from that child’s parent or legal guardian. As part of this, we need to verify that you are an adult capable of providing such consent. To do this, we charge or authorize a small amount to a credit card. This process is handled bySkyblueEnjoy Investment Pte. Ltd. We do not process your credit card information – only the third party payment processor collects credit card information. The credit card information is not retained for any reason, including future purchases or connected to in-app payment functions (if any) in the game.

What if there are changes tothe Servicein the future?

If we make any changes to the way their personal information is processed, we will notify you of those changes. You must consent to those changes before your child’s personal information will be processed for that new purpose.

Will you retain my personal information?

We will keep a record of your email address so that we can notify you of any changes to the processing of your child’s personal information, and so that we know you are a parent or legal guardian of a player when you contact us. As mentioned above, your credit card information is not processed by us, but instead only processed by a third party payment processor. We do not have access to your credit card information.

What if I do not consent?

If you do notconsent (including by providing your creditcard details for verification) then your contact information will be deleted.

How do I withdraw my consent or delete my child’s account?

You can withdraw your consent or delete your child’s account by emailing us atdpo_uamo@proximabeta.com. You can also request a copy of your child’s personal information at any time.

Our Representatives in Certain Jurisdictions

SUPPLEMENTAL JURISDICTION-SPECIFICTERMS

Some jurisdictions’ laws contain additional terms for users of theWebsite andService, 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 ourPrivacy Policyabove.

Algeria

By using theWebsite and Service, 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 theWebsite and Service) located in Singaporeand the People’s Republic of China(as described in thePrivacy Policy) where it is manually and electronically treated.

Argentina

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).

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 providinguswithyour personal information and by using theWebsite andService, 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

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.You have the right to access personal information we hold about you, how we use it, and who we share it with.

You have the right to correct any of your personal information we hold that is inaccurate.

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 theWebsite andService.

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using theWebsite andService. 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 theWebsite andService, including social media integration and in-Servicepurchases.

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).

Bangladesh

ByacknowledgingthisPrivacy 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 thisPrivacy Policy.Youalsoconsent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, toSingapore and thePeople’s Republic of China.

Brazil

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 contactus as set out inSection8(Contact). This may affect our provision of theWebsite andServiceto you.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIESAND TRANSFERRING TO COUNTRIES OTHER THAN BRAZIL, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018(as amended by the California Privacy Rights Act of 2020) (“CCPA”). For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the CCPA and do not include information excluded from the CCPA’s scope.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosedfor a business purposethe following categories of personal information from or about you or your device:

• Identifiers, such as your name as it appears on your social media profile, Open ID / user ID, IP address, device ID, device token, phone number, mailing address, email address, and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.
• Level Infinite Account Log-in information:user ID, user token, email address, username and country.
• Internet or other electronic network activityinformation, such as your information regarding your use of theService, including level, score, date and time stamps of actions, log-in and clickstream data and other Device Information as described in the mainPrivacy Policy. This information is collected directly from you and your device.
• Commercial information about any transactions within theWebsite andService such asthe purchased products and cost.This information is collected directly from you and your device and the Google Play or Apple iOS store.
• Geolocation data such as your region location when you set up your profile and choose to provide this information for theWebsite andService. This information is collected directly from you.
• Gameplay and combat information, such as user ID, game participation information,gameplay data (combat information). This information is collected directly from you and your device.
• Team and friend interaction information, such as user ID, in-game friend list, interaction information, and friend informationon social media.This information is collected directly from you and your device.
• Anti-cheating information, for both players who report suspected cheating and players suspected of cheating, such as user ID, nickname, gameplay data, report information, generated in-game video clip.This information is collected directly from you and your device.
• Audio and visual information such as your social media profile picture, photos shared in theService, and audio messages. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.
• Other information described in subdivision (e) of Section 1798.80, including information about your gender, nationality, or age. This information is collected directly from you in the context of being our consumer.

We collectand discloseyour personal information for the following purposes:

• To provide you with theWebsite andService,create andmaintain your account, provide customer service, process payments, and deliver audio and text messages.
• To allow you to participate in surveys.
• Toverify eligibility for participation in and toprovide you with aBeta version.
• To provide you with news, events and promotions with your consent.
• To conduct customer engagement activities and to allow access to in-game events.
• To perform game and app analytics, to detect bugs and to troubleshoot, and to ensure smooth operation of the Service.
• To send you in-Service notifications and announcements.
• To enable communication between users.
• To facilitate in-game friend interactions and invitations.
• To detect and prevent cheating in the Service.
• To monitor the success of our advertising campaigns.
• To improve our services, including the functionalityof theWebsite andService.
• For security and verification purposes, including to prevent and detect fraudulent activity.
• To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, seeSection3(How We Process Your Personal Information).

We discloseeach of the categories ofpersonal informationthat we collectto the following types of entities:

• Other companies within our corporate group who process your personal information in order to operate theWebsite andService.
• Other companies that provide services on our behalf and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
• Regulators,  judicial authorities,law enforcement agencies
• Entities that acquire all or substantially all of our business.

In the past 12 months, we have not soldor sharedpersonal informationof 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.

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, seethis chartin the main portion of the Privacy Policy. 

Rights under the CCPA

If you are a California residentand the CCPA does not recognize an exception that applies to you or your personal information, you have the right to:

• Request we disclose to you free of charge the following information covering the 12 months preceding your request:
  • the categories of personal information about you that we collected;
  • the categories of sources from which the personal information was collected;
  • the purpose for collecting personal information about you;
  • the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
  • the specific pieces of personal information we collected about you;
• Request we deletepersonal information we collectedfromyou,unless CCPA recognises an exception;
• Request we correct inaccurate personal information that we maintain about you; and
• Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.  

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there.If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting usasset outinSection8(Contact).

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 the following information from you: your first name, last name, address, phone number, date of birth and email address.

Under the CCPA, 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.

Questions

If you have questions or concerns regarding this Privacy Policy, please contact usas set out inSection8(Contact).

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 usas set out inSection8(Contact).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 thisPrivacy Policy.

Colombia

Your authorizationto process personal information for theWebsite andServicemay be expressed (i)inwriting, (ii) orally or (iii) through unequivocal conduct that allowsus to reasonably conclude that your authorizationhas beengranted, 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.

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 to exercise any of these rights, using the informationset outinSection8(Contact)

Egypt

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. 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 particulartothe jurisdictions specified inSection 4 (How We Store and Share Your Personal Information).

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

Instructions for the processing of your personal data after your death.You have the rightto 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 usas set out inSection8(Contact).

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.

Indonesia

By accepting and consenting to thisPrivacy Policy, you agree that we may collect, use and share your personal information in accordance with thisPrivacy Policy, as revised from time to time. If you do not agree to thisPrivacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

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 and use theWebsite andService.

In the event we fail to maintain the confidentiality of your personal information in theWebsite andService, we will notify you through the contact information provided by you or via theWebsite andService, to the extent required by local laws and regulations.

Youare 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).

Japan

If you are under the age of18, you must obtain your parent’s or legal guardian’s consent to register an account on and use theWebsite andService.

Byaccepting this Privacy Policy, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular,tothe jurisdictions specified inSection4(How We Store and Share Your Personal Information).

The categories of personal information specified intothe jurisdictions specified inSection 4 (How We Store and Share Your Personal Information)may include "special care-required personal information"(i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contactusas set out inSection8(Contact).

Kazakhstan

If you are under the age of18, you must obtain your parent’s or legal guardian’s consent to register an account on and use theWebsite andService.

Byaccepting this Privacy Policy, you consent tothe 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, toSingapore and the People’s Republic of China.

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.
• Righttoblocking / de-blocking: You have the right to request theblocking ofpersonalinformationrelatedyou,if you become aware ofa violationregarding thecollectionandprocessingyour data. If the violation has not been proved, you may request to de-block your data.
• Rightto deletion:You have the right to request deletionofyourpersonal dataif thecollectionandprocessingof your data has been conductedin violationof Kazakh laws.
• Processing of your personal information in public sources of personal data: You may request to limitor provide your consent onthe processing of your personal informationin 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 thisPrivacyPolicy, including (withoutlimitation) for the purposes of showing you personalized advertising when you use theWebsite and theService.

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 theWebsite and theService 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

In the event you are agreeing to thisPrivacy Policyin order for a minor to access and use theWebsite andService, you hereby consent to the provision of personal information of the minor to be processed in accordance with thisPrivacy Policyand you personally accept and agree to be bound by the terms in thisPrivacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with thisPrivacy Policy.

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 therequestorto 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 therequestorto ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information:You mayrequest to limit the processing of your personal information bycontacting usas set out inSection8(Contact). However, this may affect our provision of theWebsite andServiceto you.

To protect your personal information and handle complaints relating toyourpersonal information, we have appointed the following department responsible for managing and protecting your personal information.

• Our data protection officer, responsible for the management and safety of your personal information

• Telephone: +603-22872388
• Email:dpo_uamo@proximabeta.com

Mexico

Some of the purposes of processingstated above are forvoluntarypurposes,includingto 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.In general, we do not require your consent to carry out the transfers detailed inSection4(How We Store and Share Your Personal Information). In any case, by using theWebsite andServiceand providing us with your personal data, you agree to the data transfers detailedthereinthat require your consent.

Tounderstandmore aboutand exerciseyour rightsto“Access”, “Correction”,“Erasure”, “Objection”,“Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us as set outinSection8(Contact).

Morocco

We collect information for purposes strictly necessary for the proper use of the Website and the Service.

By acceptingthis PrivacyPolicy,you explicitly accept that your personal data may be subject to processing by the Website and the Service.

Kindly note:

• the identity of the Data Controller isProxima BetaPte.Limited, email:dpo_uamo@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”.

New Zealand

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.

You have the right to access personal information we hold about you, how we use it, and who we share it with.

You have the right to request the correction of any of your personal information we hold that is inaccurate.

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 theWebsite andService.

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).

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.

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.

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.

• Data Protection Team, responsible for the management and safety of your personal information
• Contact:dpo_uamo@proximabeta.com

Philippines

You are entitled to the following rights:

• Right to be informed.You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
• Right to object.You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
• Right to access.You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
• Right to rectification.You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
• Right to erasure or blocking.You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

By consenting to this Privacy Policy, you consent to us:

• collecting and processing your personal information as described inSection3(How We Process Your Personal Information);
• sharing your personal information with third parties, companies withinour corporategroup, 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 inSection4(How We Store and Share Your Personal Information)

Qatar

If you are using theWebsite and Servicein 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 thisPrivacy Policy.

Republic of Korea

We provide your personal information to third parties as described below:

For the performance of the services detailed in thisPrivacy Policy, we delegate the processing of your personal information to the following professional service providers:

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

Data Destruction

Personal information is retained in accordance with the data retention periods asdetailed in section“Data Retention”.With the exception of the personal information set out below,personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

The personal information detailed in section“Data Retention”are required to be retained pursuant to the following laws:

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 Information Protection Act (“PIPA”). You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA. You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Additional Use and Provision of Personal Information

In accordance with the PIPA, we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc. We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information. Specific considerations are as follows:

• whether the additional use/provision is related to the initial purpose of the collection;
• whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;
• whether the additional use/provision unfairly infringe on the interests of the data subject; and
• whether the necessary security measures such as pseudonymization or encryption were taken.

Domestic Privacy Representative

Pursuant to the Article 32-5 of Network Act and Article 39-11 of the amended PIPA, the information regarding the domestic agent is as follows:

• Name: Kite Bird KoreaYuhanHoesa
• Address: 25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro2-ga), Korea
• Telephone:+82-2-2185-0926
• Email:dpo_uamo@proximabeta.com

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.

• Data Protection Department, responsible for the management and safety of your personal information
• Telephone: +82-2-2185-0926
• Email:dpo_uamo@proximabeta.com

Serbia

Our designated local representative in Serbia isKaranovic& 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.

• Name: Karanovic & Partners o.a.d. Beograd
• Address:Resavska23, Belgrade, 11000, Serbia
• Telephone Number: +381 11 3094 200

• E-mail:local.representative@karanovicpartners.com

Singapore

By clickingthe button to proceed, you consent to the cross-border transfer of yourinformation to any country where we have databases or affiliates and, in particular,the locations specifiedinSection4(How We Store and Share Your Personal Information).

You have the right to access your personal information, how we use it, and who we share it with

You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contactedas set out inSection8(Contact).

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it atinforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33HoofdStreet Forum III, 3rd FloorBraampark, 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 theWebsite and Service.

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 theWebsite and Service.

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 theWebsite and Service.

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 usas set out inSection8(Contact).

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA isas set out inthe section“Our Representatives in Certain Jurisdictions” andcan be contacted via email. Please include the word “Thailand” in the subject line of your email.

Türkiye

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):

• learn whether or not your personal data has been processed;
• request information about processing if your personal data has been processed;
• learn the purpose of processing of your personal data and whether they have been used accordingly;
• know the third parties in the country or abroad to whom personal data has been transferred;
• request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
• request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
• object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems;and
• demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

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.

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 countriesor regionsother than Ukraine, to the extent and for the purposesprovidedinthis Privacy Policy.

Virginia

This section applies to Virginia residents covered by the Virginia Consumer Data Protection Act (“VCDPA”). For purposes of this section, “personal data” and “sensitive personal data” have the meanings given in the VCDPA and do not include information excluded from the VCDPA’s scope.

If you are a Virginia resident and the law does not recognize an exception that applies to you or your personal data, you have the right to:

• request that we disclose to you the personal data that we collect, use, or disclose, and information about our data practices.
• request we deletepersonal data we collectedfromyou,unless the law recognises an exception;
• request we correct inaccurate personal data that we maintain about you;
• be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the law.

We do not collect sensitive personal data about you.We also do not process personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there.If you are a Virginia resident to whom the VCDPA applies, you may also exercise your rights, if any, regarding other data by contacting usas set out inSection8(Contact).

How to Appeal Decision on Your Request

If you would like to appeal a decision on your request to exercise any right you have under the VCDPA, you maycontact usas set out inSection8(Contact).