Welcome to Arena Breakout!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with Arena 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 you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Website and the 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 this Privacy Policy describes, please do not provide your information when requested and stop using the Website and the Service. By using the Website and the Service, you are acknowledging how we process your personal information as described in this Privacy Policy.

For the purpose of data protection laws, the data controller of your personal information in relation to the Website and Service is Proxima Beta Pte. 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 found here. You can also reach out to our data protection officer at dpo_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 the Website and the Service 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, please contact us.

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
Japan	18
Kazakhstan	18
Kuwait	21
Macau	18
Malaysia	18
Mexico	18
Morocco	18
Myanmar	18
New Zealand	16
Nigeria	13
Philippines	18
Qatar	18
Republic of Korea	14
Saudi Arabia	18
Serbia	15
Singapore	13
South Africa	18
Sri Lanka	18
Switzerland	14
Thailand	20
Tunisia	18
Türkiye	18
United Arab Emirates	21
United Kingdom	13
United States	13

3. How We Process 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 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.

Personal Information	Use	Legal Basis (where applicable)
For the Website
Information you provide to us (either directly or through a third party)
IP address	We use this information to detect your location and to provide you with the relevant content specific to your region, and to analyse global player allocation.	Necessary to perform our contract with you to provide the Website.
Survey information (optional): email, country or region of residence, and gaming habits and preferences, and any other responses you choose to provide	With your consent, we use survey information to allow you to participate in surveys about the Service to improve the Service, and to register for the Service. With your consent, we may send you news, events and promotions related to the Service.	We collect and use this information with your consent.
H5 activity analysis information: user identifier, country and region, browser version information, Open ID, IP address	We use this information to measure performance indicators of H5 activities.	It is in our legitimate interest to understand the performance of the H5 activity.
H5 record information: Open ID, in-game behaviour record, website behaviour	We use this information to verify that conditions for the event reward are met, and to optimize the event format and effect.	Necessary to perform our contract with you to provide the Service where you choose to join an H5 event.
For the Service
Information you provide to us (either directly or through a third party)
Account registration information: Social Media information (if you choose to log in via your account with these networks) LEVEL INFINITE PASS: user ID, username, user token, email address, country (see https://account.levelinfinite.com/privacypolicy.html) Facebook: Facebook UID, nickname, profile picture, user token, Open ID Google Play: user ID, nickname, profile picture, user token and Open ID Apple account login: user ID, nickname, profile picture, user token and Open ID X (previously known as Twitter): user ID, nickname, profile picture, user token and Open ID LINE: user ID, nickname, profile picture, user token and Open ID QQ: nickname, profile picture, user token and Open ID WeChat/Weixin: nickname, profile picture, user token and Open ID Guest login: guest ID and Open ID	We use this information to allow you to register and create your account for the Service (including by linking your game account to another account of an eligible platform) in accordance with your request, log in to the Service and participate in game activities and receive notifications of the Service.	Necessary to perform our contract with you to provide the Service.
Friends list (Facebook): your friends’ Facebook user ID, names, profile pictures and Open ID	We use this information to allow you to connect with friends and share Service content.	Necessary to perform our contract with you to provide the Service.
Survey information (via IMUR): your email, country or region of residency, gaming habits and preferences (including recently played games, gameplay frequency, favourite game categories and experience, language preference, evaluation and comments towards the Service), and other survey responses content that you may choose to provide	With your consent, we use the survey information to allow you to participate in surveys about the Service to improve the Service.	We use this information with your consent.
Survey information (provided by users to third party service providers): user ID, age, gender, contact (social media, email address, phone number etc.), IP address, region, device information (model, storage, etc.), gaming experience and preferences, and any other responses you choose to provide	With your consent, we may deliver the survey information collected to third party service providers to conduct customer engagement activities, such as carrying out playtest sessions, surveys and interviews.	We collect this information with your consent.
Information generated as part of the Service
XWID: Your XWID, which is generated by us	We use this information to perform general/overall game analytics (not confined to error fixing or debugging), and to enable you to use the Service as a guest user.	It is in our legitimate interest to ensure the functioning of our Service and to allow users to use the Service as a guest user.
SDK performance information: information about the interactions between the SDKs, errorcode, error message, SDK name, SDK version, request url, response body, sequence ID, stage, log	We use this information to analyse the performance of the SDKs within the Service in order to ensure the smooth operation of the Service.	It is in our legitimate interest to ensure the smooth operation of the Service.
Game data: Open ID, IP address, device model, gameplay data (level, nickname)	We use this information to enable you to use the Service, to participate Service events, and to undertake statistical analysis and quality monitoring.	Necessary to perform our contract with you to provide the Service.
Merit Score information: Open ID, gameplay data (game behaviours)	We use this information to identify behaviours in violation of the Service’s Code of Conduct, and to calculate and display the Merit Score. For more information, please refer to the Rules on Toxic Behaviour and the Corresponding Penalties.	It is in our legitimate interest to ensure the integrity of the Service and protect users from being subject to prohibited conduct.
Combat performance information: user ID, team ID, gameplay data (combat information)	For the classic game mode, we use this information to improve resource distribution in the battlefield.	It is in our legitimate interest to improve the Service.
Combat Matchmaking Information: user ID, gameplay data (login frequency/time, level, ranking information, achievements, performance), reporting (by other users) and punishment record	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 the Service.
In-game events via Gamelet: Open ID, role ID	We use this information to enable you to access in-game events via Gamelet.	Necessary to perform our contract with you to provide the Service.
In-game events via Pandora: role name, role ID, Open ID, platform ID, level, language, country or region, device model, operating system, CPU type, system memory size, network type, gameplay data	We use this information to enable you to access in-game events via Pandora.	Necessary to perform our contract with you to provide the Service.
Friend interaction information: nickname, interaction information such as time of becoming in-game friends, 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 in-game friend interactions.	Necessary to perform our contract with you to connect you with your friends.
Friend recommendations and ranking information: country or region, language, social media access platform, mic status (on/off), ranking information, preferred map, Ping (i.e. internet performance), nickname, and avatar	We use this information to recommend in-game friends to you and to provide you with a leaderboard.	Necessary to perform our contract with you to connect you with your friends.
Offline team invitation information: User ID, in-game friends list, Facebook name, Facebook ID, Facebook profile picture, whether you log in via Facebook, 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. We access your Facebook friends list with your consent.
Leaderboard highlights information (in-game and social media): Ranking, level, user ID, username, team name, avatar, login IP address, points, selected country or region for participation by player, value of in-game items collected, total number of eliminations for MVP	We use this information to showcase highlights of top players in-game and/or on social media platforms.	It is in our legitimate interest to ensure the integrity of high-scoring players is supported by appropriate evidence, and to foster a more engaging gaming environment.
Game performance information: Open ID, phone memory, GPU information, CPU model, CPU usage rate, device brand, network traffic, device system version, screen resolution, ROM, RAM, device manufacturer, CPU architecture, remaining memory, device model, system time, UUID, whether Root, system startup time, battery status, FPS, SDK version, network type, application version, application package name	We use this information to monitor your game performance.	It is in our legitimate interest to ensure the smooth operation of the Service.
Routing information and network latency information: IP address, WiFi status, Wifi parameters, device model, device operating system version, Open ID, cellular status, cellular parameters, network type	We use this information to analyse your WiFi network quality and analze gaming performance quality on different device models.	It is in our legitimate interest to ensure the smooth operation of the Service.
Device class analysis information: CPU model, GPU information, phone memory, device brand, RAM, ROM, device model, device name	We use this information to analyse device class and to change device class through remote control.	It is in our legitimate interest to change device class through remote control.
Buried data analysis information: CPU model, GPU information, device brand, client exports IP, device manufacturer, RAM, ROM, CPU architecture, remaining memory, device model, device name	We use this information to report on and analyse buried data.	It is in our legitimate interests to use this information to report on buried data.
Success rate and performance monitoring information: Open ID, device model, device name	We use this information to: monitor the success rate for requesting permission from and accessing the control server; monitor your network and performance in battle server; and monitor the success rate for accessing lobby server, battle server, and pay server.	It is in our legitimate interests to use this information to monitor the success rate to ensure smooth operation of the Service.
Performance information: Open ID, device brand, device model, device name, device manufacturer	We use this information to: monitor system down frequency and analyse device performance; and and optimise game performance on your device.	It is in our legitimate interests to optimize Service performance on your device.
Service analysis information: Phone memory, device brand, device system version, device manufacturer, ROM, screen resolution, RAM, system time, device model, device ID, device name, CPU model, CPU architecture, app list, SDK version, IP address, mobile network code, network type, application package name, application version	We use this information to analyse your device performance and improve your Service experience.	It is in our legitimate interests to improve your Service experience.
Notification information: In-Service notifications: Open ID, device ID System notifications: device token, Firebase Cloud Message token	We use this information to send you in-Service notifications and announcements.	It is in our legitimate interest to notify you about announcements, updates or information relating to the Service.
Compliance Information: Email verification: date of birth, Open ID, token, username and email address Credit card verification: Open ID, token, region, username, credit card number, expiry date, CVC, family name, given name, email address, billing address Your date of birth is only stored device-side and is not transferred to us.	We use this information to verify your eligibility to use the Service and to comply with applicable laws.	It is in our legitimate interest to ensure compliance with applicable age-gating rules.
Data analytics information: event name, stage number, stage name, stage status, stage error code, extra json and stage time	We use this information to: report key statistics from the processes of log-in and Service update; and understand the success rate of the log-in process and the update process.	It is in our legitimate interest to use this information to improve the Service.
Crash information: device name, device model, phone memory, CPU usage rate, CPU model, device system version, device brand, ROM, RAM, CPU architecture, whether root, remaining external SD card space, remaining memory, whether it is running in the simulator, running process information, system time, XWID, process name, network type, application data (version, package name), SDK version, SDK version number and application name	We use this information to locate and resolve crash issues.	It is in our legitimate interest to use this information to ensure the security and integrity of the Service.
Functional quality monitoring information: Open ID, device brand, device model, device standard, device name, client exports IP, device manufacturer, SDK version, IP address, application version, buried data reporting, mobile network code, network type	We use this information to locate game faults on your device.	It is in our legitimate interest to use this information to improve the Service.
Account deletion data: email address, region, Open ID and user token	We use this information to allow you to delete your account.	Necessary to perform our contract with you to provide the Service and delete your account in accordance with your instructions.
Game version update information: Open ID, device model, device name, login channel ID	We use this information to provide you with Service updates and to allow you to download in-game resources.	Necessary to perform our contract with you to provide the Service.
In-Service screenshot information: whether you have taken an in-game screenshot, and the in-game screenshot if applicable (which will contain any content displayed at the time)	We use this information to facilitate your sharing of any in-game screenshot on social networks. 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.
Real time voice chat data: Open ID, device name, device model, client exports IP, device brand, UUID, device manufacturer, system time, SDK version, IP address, network type	We process this information to facilitate your real-time voice chat with users. We also process and review this information if we suspect any inappropriate behaviour. We do not store this information on our servers.	Necessary to perform our contract with you to provide the Service and allow you to use voice chat with other users. It is also in our legitimate interest to ensure the safety, integrity and fairness of the Service and to allow users to enjoy the voice chat function.
Voice message data: Open ID, device name, device model, client exports IP, UUID, system time, SDK version, IP address, network type and voice file	We process this information to allow you to upload and send voice messages to other users. We also process and review this information if we suspect any inappropriate behaviour.	Necessary to perform our contract with you to provide the Service and enable communication between users. It is also in our legitimate interest to ensure the safety, integrity and fairness of the Service and to allow users to enjoy the voice chat function.
Voice-to-text information: Open ID, device name, device model, client exports IP, IP address, network type	We process this information to provide the function of converting audio information into text in voice messages. We also process and review this information if we suspect any inappropriate behaviour.	Necessary to perform our contract with you to provide the Service and enable communication between users. It is also in our legitimate interest to ensure the safety, integrity and fairness of the Service and to allow users to enjoy the voice chat function.
Text chat information (lobby chat and message chat): Open ID, role ID, text chat	We process this information to provide you with the functions of lobby chat (public text chat) and message chat (private text chat).	Necessary to perform our contract with you to provide the Service and enable communication between users.
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.	It is in our legitimate interest to ensure the integrity of the Service and protect users from being subject to prohibited conduct.
Complaint verification information: Players who report suspected cheating: user ID, nickname, profile picture, region, log-in channel, report information (such as category, description, battle ID, time, results) Players suspected of cheating: user ID, nickname, gameplay data (such as number of kills, rank, scores), generated in-game video clip Report records can also be viewed on the Website.	We use this information to review complaints and determine whether users suspected of cheating have cheated in the Service, and to assist with customer support.	It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Service.
Anti-cheating security-related information: Open ID, system version, brand, CPU architecture, system boot time, country code, language, Android device information (whether Root, whether it is running in the simulator, installed APK information, running process information, module information of process, file name list under SD card application cache directory, application package name, process name, application version, start up time, target feature file of SD card, host file, in-game screen, plug-in real-time detection, upload suspicious apk files within the scope of system authority, critical system library files), user ID, nickname, user game property, user key operations in game	We use this information for anti-cheating purposes, including to detect and observe cheating behaviours and monitor the presence and operation of suspected cheating activity or anomalies.	It is in our legitimate interest to use this information to detect and prevent cheating in the Service.
Anti-cheating information: Open ID, device brand, device model, device name, device manufacturer, device fingerprint, product name, manufacturer, hardware name, device ID	We use this information to detect whether the terminal device is an emulator and to combat plug-ins and cheating.	It is in our legitimate interest to use this information to detect and prevent cheating in the Service.
Anti-cheat analysis information: player behaviour in the game such as movement, shooting and use of game items, player avatar appearance in the game such as name and skins	We use this information to detect cheating.	It is in our legitimate interest to use this information to detect and prevent cheating in the Service.
Account security-related information: Device ID, device application version, battery information, screen DPI, system file information, screen information, device statistics, XID (for guest users), GPU version number	We use this information to resolve account security issues, such as account retrieval and risk detection.	It is in our legitimate interest to use this information to ensure account security for your account.
Data analytics (Adjust): Technical data including pseudonymized (hashed) IP address, IDFA, Google Advertising ID, installation and first opening of an app on user’s mobile device, user’s interactions within an app (in-app purchases, registration), information regarding which advertisings a user has seen.	We use this information to monitor the success of our advertising campaigns.	It is in our legitimate interest to carry out data analytics and profiling for ad attribution purposes to understand how our users interact with advertisements.
Data analytics (Firebase): Default Firebase implementation collects: User device dimensions and in-app events such as number of users and sessions, session duration, operating systems, device models, geography, first launches, app opens, app updates, in-app purchases Firebase collects the following device dimensions: age, App Store, app version, country, device brand, device category, device model, first open time, gender, interests, language, new/established, OS version Firebase automatically collects the following in-app events: advertising analytics such as ad clicks, ad exposure, ad impression, ad query, application analytics such as app usage, app clearance, app crashes, app removal, app payment analytics, app update and use analytics, website usage analytics, such as web clicks, browser downloads, notification, video progress, search analytics Ad ID Firebase instance ID: Open ID Firebase installation ID	We use this information for app performance analytics and to monitor the success of our advertising campaigns.	It is in our legitimate interest to use this information to monitor the effectiveness of our advertisements and to provide a better Service experience.
Data analytics (Facebook): Contact information: information that personally identifies individuals, including names, email addresses, and phone numbers (used for matching purposes only) Event data: visits to sites, installations of apps, and purchases of products Hashed data: including email addresses and phone numbers	We use this information to monitor the success of our advertising campaigns.	It is in our legitimate interest to use this information to monitor the effectiveness of our advertisements to provide better Service experience.
Function game dedicated server logs information: your game ID, game nickname, game property, and key operations in the Service	We use this information to help developers solve bugs in game dedicated server.	It is in our legitimate interest to locate and solve bugs in game dedicated servers.
Function game server logs information: your game ID, game nickname, game property, game level, game task list, game battle records, team information, and key operations in the Service	We use this information to help developers to solve bugs in game server.	It is in our legitimate interest to locate and solve bugs in game servers.
Payment information (in-app): Open ID, country, role ID, CPU model, device model, currency, SDK version, application version, network type, IDFV, purchase amount	We use this information to enable you to use the payment function in the Service via Google Play or iOS Apple Store.	Necessary to perform our contract with you to provide the Service, information about your purchase history and to restore purchased items.
Payment information (third party platforms): order number, amount, subscription ID and currency	We use this information to enable you to make payments in-game on the following platforms: Amazon App Store, OneStore, Galaxy Store and App Gallery.	Necessary to perform our contract with you to provide the Service.
Payment information (Midasbuy): purchased items and their costs, time, date and currency of the purchase, order ID, Open ID, player ID, country, game account balance and purchase history	We use this information to enable you to use the payment function in the Service via Midasbuy.	Necessary to perform our contract with you to provide the Service, information about your purchase history and to restore purchased items.
Tlog information: Open ID, role ID, user nickname	We use this information to understand your game behavior to optimize your experience in the Service.	It is in our legitimate interest to optimize your experience in the Service.
Customer Support: Game account and contact information (including your nickname, profile picture, open ID, country selected by you during registration, login channel, social media account, mobile phone, email address, registration time); Login status verification information; Device information; Game data: Game character information (including your role name and role ID, game data and records, frequency of playtime, game history), and in-game data (including items, purchase and top-up information, penalties, activities, game match data, in-game friends); Customer service log data (including Open ID, ticket date, type of request); Feedback on app store; Any other details/information (including any documents/media) that you choose to provide to us as part of your ticket, query or review	We use this information to improve our services and provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the Service.
Account retrieval information: Email address and/or associated social media account (if you elect to provide this information)	We use this information to verify personal information when your account information is lost and you wish to retrieve your account details.	Necessary to perform our contract with you to provide and support the Service.
Beta Version 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 version account and whether you have cheated in the Game.	If you seek to participate in our Beta version, we use this information to verify eligibility for participating in the Beta version and to provide you with the Beta version.	Necessary to perform our contract with you to provide a Beta version.
H5 Event Data (only if such events are applicable to your jurisdiction): User ID, nickname, email address, IP address, and crash / error logs from the game	We use this information to provide you with any events within the Service that you choose to participate in.	Necessary to perform our contract with you to provide and support the Service.
Elimination reports information: Combat ID, map ID, player ID, player's avatar at end of combat, player's weapons and equipment at end of combat.	We use this information to provide you with elimination reports.	Necessary to perform our contract with you to provide and support the Service.
Battle history-related information: Map ID, character ID, character avatar, locations passed through during the game, and operation behaviour during the game.	We use this information to provide you with more information about your game history and to allow you to conveniently share your game battle history.	Necessary to perform our contract with you to provide and support the Service.
Phone notification information: Phone number, open ID, user’s region	We use this information to provide you with SMS notifications about the Service and related events with your consent.	We use this information with your consent.
Clipboard feature information: Username, user ID	We use this information to allow you to copy username and user ID to send team invitations to non-logged-in friends in a more convenient manner. We do not store this information on our servers.	Necessary to perform our contract with you to provide and support the Service.

4. How We Store and Share Your Personal Information

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

Our servers for the Website and the Service are located in Singapore. We also have support, engineering and other teams who may support the Website and the Service, including in Singapore and the People’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 or taking into account adequacy assessments.

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

Third parties that provide services in support of the Website and Service, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Website and Service, 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 the Website and Service (i.e., for the purpose(s) described above).
Companies within our corporate group who process your personal information solely for the purpose of providing the Website and Service to you. All such group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
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 as exchanging 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. The Security of Your Personal Information

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 Website and Service or otherwise via the Internet; any transmission is at your own risk.

6. Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, 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.

Personal Information	Retention Policy
For the Website
Survey information Email address	Stored for 90 days or deleted within 30 days of your request, whichever is earlier.
IP address	Data will not be stored. Information will be automatically deleted once location of user has been detected.
H5 activity analysis information H5 record information	Stored for 1 year or deleted within 30 days of your request, whichever is earlier.
For the Service
Account registration information Friends list (Facebook) XWID SDK performance information Data analytics information Payment information (in-app) Payment information (Midasbuy) Payment information (third party platforms) Customer support information Account retrieval information Game data Merit Score information Combat performance information Combat matchmaking information Friend interaction information Friend recommendation and ranking information Offline team invitation information Reported chat data Complaint verification information Compliance information Crash information Game version update information Performance information In-Service notifications Anti-cheating security-related information Account security-related information Success rate and performance monitoring information Game performance information Device class analysis information Buried data analysis information Function game dedicated server logs information Function game server logs information TLog information Survey information (via IMUR) Survey information (provided by users for customer engagement) Data analytics (Adjust) Data analytics (Firebase) Data analytics (Facebook) Elimination reports information Battle history-related information Phone notification information	Stored for the lifetime of your use of the Service and then deleted within 30 days after the end of the Service, or deleted manually within 30 days of your request, whichever is earlier.
Leaderboard highlights information (in-game and social media)	Where the leaderboard is connected to an event, this is stored for 6 months after the end of the event. Where the leaderboard is not connected to an event, this is stored for the lifetime of your use of the Service and then deleted within 30 days.
In-Service screenshot information	Not stored. This is processed device-side only and is not transferred to us.
Clipboard feature information	Not stored. This is processed device-side only and is not transferred to us.
Service analysis information Routing information and network latency information	90 days or deleted within 30 days of your request.
Anti-cheating information Functional quality monitoring information	Stored for the lifetime of your use of the Service or deleted manually within 7 days of your request, whichever is earlier.
Anti-cheat analysis information	90 days.
In-game events via Gamelet and Pandora	180 days then automatically deleted.
Account deletion data	Retained during the lock-up period of 30 days.
System notifications	This is not stored on our servers.
Text chat information (lobby chat and message chat)	Lobby chat: text chat information will not be stored. Message chat: If the recipient has checked the message, the data will not be stored on the Service servers. If the recipient has not checked the message, the text chat information will be stored on the Service servers after it is sent and until the recipient has read the message, or deleted within 30 days upon your request, whichever is earlier.
Real-time voice chat data	Voice data is collected real-time and will not be stored on the Service servers.
Voice message data	Voice message data is collected real-time and will be stored on gvoice server for 7 days and stored on your device locally. Voice message data will be stored on the Service servers until the intended recipient has listened to it.
Voice-to-text information	Voice-to-text information is collected real-time and will be stored on gvoice server for 7 days and stored on your device locally. It will not be stored on the Service servers.
Beta Version Account Authentication Information	Stored until 30 days after the termination of the Beta version or 7 days upon your request of deletion, whichever is earlier.
H5 Event Data (only if such events are applicable to your jurisdiction)	90 days after the event has ended or within 30 days of your request, whichever is earlier.

7. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Website and Service. 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 these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact 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 your Service account. 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 at dpo_uamo@proximabeta.com, and we 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 access to the Service for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.

8. Contact

Please get in touch with us if you have any questions. You can reach us 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 to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

9. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify 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 can participate 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 does the Service process?

Arena Breakout is a survival shooting mobile game. 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. Players can 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 to the 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);
leaderboard information for in-game and/or social media leaderboards (such as ranking, level, user ID, username, team name, avatar, login IP address, points, selected country or region for participation by player, value of in-game items collected, total number of eliminations for MVP); and
other game, ranking and payments information.

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

Does the Service process 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 as Arena 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 by Skyblue Enjoy 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 to the Service in 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 not consent (including by providing your credit card 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 at dpo_uamo@proximabeta.com. You can also request a copy of your child’s personal information at any time.

SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS

Some jurisdictions’ laws contain additional terms for users of the Website and Service, 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 Website 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 the Website and Service) located in Singapore and the People’s Republic of China (as described in the Privacy 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 providing us with your personal information and by using the Website and Service, 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 the Website and Service.

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

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

By acknowledging 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. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore and the People’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 contact us as set out in Section 8 (Contact). This may affect our provision of the Website and Service to 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 PARTIES AND TRANSFERRING TO COUNTRIES OTHER THAN BRAZIL, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

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 as set out in Section 8 (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 this Privacy Policy.

Colombia

Your authorization to process personal information for the Website and Service may be expressed (i) in writing, (ii) orally or (iii) through unequivocal conduct that allows us to reasonably conclude that your authorization has been 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.

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 information set out in Section 8 (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 particular to the jurisdictions specified in Section 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 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 as set out in Section 8 (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 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.

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 the Website and Service.

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

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).

Japan

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 Website and Service.

By accepting 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, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

The categories of personal information specified in to the jurisdictions specified in Section 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 contact us as set out in Section 8 (Contact).

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 Website and Service.

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 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.
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, including (without limitation) for the purposes of showing you personalized advertising when you use the Website and the Service.

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 Website and the Service 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 this Privacy Policy in order for a minor to access and use the Website and Service, 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.

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 contacting us as set out in Section 8 (Contact). However, this may affect our provision of the Website and Service to you.

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.

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 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. In general, we do not require your consent to carry out the transfers detailed in Section 4 (How We Store and Share Your Personal Information). In any case, by using the Website and Service and providing us with your personal data, you agree to the data transfers detailed therein that require your consent.

To understand more about and exercise your rights to “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 out in Section 8 (Contact).

Morocco

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

By accepting this Privacy Policy, 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 is Proxima Beta Pte. 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 the Website and Service.

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 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.

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 in Section 3 (How We Process Your Personal Information);
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 Section 4 (How We Store and Share Your Personal Information)

Qatar

If you are using the Website and Service 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.

Republic of Korea

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

Name of Recipient (and contact information)	Types of Personal Information provided	Purpose of Use by Recipient	Period of Retention and Use by Recipient
SEKG (SENSING EMOTIONS AND KNOWLEDGE GROUP S.L) (https://antidote.gg/sekg-gamers-privacy-policy/); Gamegulu LLC; Yiyo Market Research Limited	Contact information collected from surveys	To conduct customer engagement activities such as carrying out playtest sessions, surveys and interviews with users of the Service	For the data retention period specified under “How We Store and Share Your Personal Information”
Google Analytics (Firebase) (https://firebase.google.com/support)	Analytics data	Data analytics	For the data retention period specified under “How We Store and Share Your Personal Information”
Facebook (Analytics) (https://www.facebook.com/help/ contact/507739850846588)	Contact information, event data and hashed data	Re-targeting marketing to train algorithm to find high potential target audience	For the data retention period specified under “How We Store and Share Your Personal Information”
Adjust (https://www.adjust.com/terms/privacy-policy/)	Advertising information	To monitor the success of our advertising and marketing programs	For the data retention period specified under “How We Store and Share Your Personal Information”

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

Delegatee	Description of Delegated Services
Midas, Amazon Web Services Inc., OneStore, Samsung Electronics Co., Ltd., Huawei Technologies Co. Ltd	Provide payment function
Skyblue Enjoy Investment Pte. Ltd	Process credit card payment for verifying parental consent
Tencent Cloud (cloudlegalnotices@tencent.com)	Storage of personal information

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

Recipient (Contact Information of Information Manager)	Country to which Your Personal Information is to be Transferred	Date and Method of Transfer	Types of Your Personal Information to be Transferred	Purposes of Use by Recipients	Period of Retention of Use by Recipient
Tencent Cloud (cloudlegalnotices@tencent.com)	Singapore, Germany	Transferred via information and communications network at the time of service use	All personal information set out in Section 3 (How We Process Your Personal Information).	Storage of personal information	For the data retention period specified under “How We Store and Share Your Personal Information”
SEKG (SENSING EMOTIONS AND KNOWLEDGE GROUP S.L) (https://antidote.gg/sekg-gamers-privacy-policy/)	Spain unless otherwise described in the service provider’s privacy policy	Transferred via information and communications network at the time of service use	Contact information collected from surveys	To conduct customer engagement activities such as carrying out playtest sessions, surveys and interviews with users of the Service	For the data retention period specified under “How We Store and Share Your Personal Information”
Gamegulu LLC;	United States unless otherwise described in the service provider’s privacy policy
Yiyo Market Research Limited	Hong Kong unless otherwise described in the service provider’s privacy policy
Google Analytics (Firebase) (https://firebase.google.com/support)	United States unless otherwise described in the service provider’s privacy policy	Transferred via information and communications network at the time of service use	Analytics data	Data analytics	For the data retention period specified under “How We Store and Share Your Personal Information”
Facebook (Analytics) (https://www.facebook.com/help/contact/507739850846588)	United States unless otherwise described in the service provider’s privacy policy	Transferred via information and communications network at the time of service use	Contact information, event data and hashed data	Re-targeting marketing to train algorithm to find high potential target audience	For the data retention period specified under “How We Store and Share Your Personal Information”
Adjust (https://www.adjust.com/terms/privacy-policy/)	Europe (Frankfurt and Amsterdam) and the United States	Transferred via information and communications network at the time of service use	Advertising information	To monitor the success of our advertising and marketing programs	For the data retention period specified under “How We Store and Share Your Personal Information”
Skyblue Enjoy Investment Pte. Ltd	Singapore	Transferred via information and communications network at the time of service use	Payment card information	For verifying payment card information in relation to parental/guardian consent	For the data retention period specified under “How We Store and Share Your Personal Information”
Amazon Web Services Inc. (https://aws.amazon.com/privacy/)	United States	Transferred via information and communications network at the time of service use	Payment information	For making payments in-game on the platform	For the data retention period specified under “How We Store and Share Your Personal Information”
Huawei Technologies Co. Ltd (https://www.huawei.com/en/privacy-policy)	PRC	Transferred via information and communications network at the time of service use	Payment information	For making payments in-game on the platform	For the data retention period specified under “How We Store and Share Your Personal Information”
Midas (privacy@midasbuy.com)	Singapore and United States	Transferred via information and communications network when payment is made	Payment information	For making payments in-game	For the data retention period specified under “How We Store and Share Your Personal Information”
Discord Inc. (https://discord.com/privacy)	United States	Transferred via information and communications network at the time of service use	Leaderboard highlights information	To display the leaderboard	For the data retention period specified under “How We Store and Share Your Personal Information”
X Corp. (https://twitter.com/en/privacy)	United States unless otherwise described in the service provider’s privacy policy	Transferred via information and communications network at the time of service use	Leaderboard highlights information	To display the leaderboard	For the data retention period specified under “How We Store and Share Your Personal Information”
Meta Platforms Inc. (https://www.facebook.com/privacy/policy/ and https://help.instagram.com/155833707900388)	United States unless otherwise described in the service provider’s privacy policy	Transferred via information and communications network at the time of service use	Leaderboard highlights information	To display the leaderboard	For the data retention period specified under “How We Store and Share Your Personal Information”
YouTube, LLC (https://policies.google.com/privacy?hl=en)	United States unless otherwise described in the service provider’s privacy policy	Transferred via information and communications network at the time of service use	Leaderboard highlights information	To display the leaderboard	For the data retention period specified under “How We Store and Share Your Personal Information”

You may refuse the overseas transfer of your personal information by contacting our Data Protection Department. If you refuse the overseas transfer of your personal information, your personal information will not be transferred overseas. However, you may not be able to use our services for which overseas transfer of personal information is necessary.

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed 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:

Act on the Consumer Protection in Electronic Commerce, Etc.

Article 6 of the Act on the Consumer Protection in Electronic Commerce

In an electronic commerce or a mail-order sale:

Records regarding labelling and advertising (6 months)
Records regarding execution or withdrawal of a contract (5 years)
Records regarding the payment of a price and the supply of goods and services (5 years)
Records regarding customer services or dispute resolution (3 years)

Protection of Communications Secrets Act

Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications Secrets Act

Log records, IP address (3 months)
The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

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 Korea Yuhan Hoesa
Address: 25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea
Telephone: +82-2-2185-0926
Email: dpo_uamo@proximabeta.com

Contact

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 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.

Name: Karanovic & Partners o.a.d. Beograd
Address: Resavska 23, Belgrade, 11000, Serbia
Telephone Number: +381 11 3094 200

E-mail: local.representative@karanovicpartners.com

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 locations specified in Section 4 (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 contacted as set out in Section 8 (Contact).

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 Website 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 the Website 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 the Website 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 us as set out in Section 8 (Contact).

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 “Our Representatives in Certain Jurisdictions” and can 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:

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
Tencent Cloud (cloudlegalnotices@tencent.com)	Singapore, Germany	Storage of personal information	All personal information set out in Section 3 (How We Process Your Personal Information).
SEKG (SENSING EMOTIONS AND KNOWLEDGE GROUP S.L) (https://antidote.gg/sekg-gamers-privacy-policy/)	Spain unless otherwise described in the service provider’s privacy policy	To conduct customer engagement activities such as carrying out playtest sessions, surveys and interviews with users of the Service	Contact information collected from surveys


Gamegulu LLC;	United States unless otherwise described in the service provider’s privacy policy
Yiyo Market Research Limited	Hong Kong unless otherwise described in the service provider’s privacy policy
Google Analytics (Firebase) (https://firebase.google.com/support)	United States unless otherwise described in the service provider’s privacy policy	Data analytics	Analytics data
Facebook (Analytics) (https://www.facebook.com/help/contact/507739850846588)	United States unless otherwise described in the service provider’s privacy policy	Re-targeting marketing to train algorithm to find high potential target audience	Contact information, event data and hashed data
Adjust (https://www.adjust.com/terms/privacy-policy/)	Europe (Frankfurt and Amsterdam) and the United States	To monitor the success of our advertising and marketing programs	Advertising information
Skyblue Enjoy Investment Pte. Ltd	Singapore	For verifying payment card information in relation to parental/guardian consent	Payment card information
Amazon Web Services Inc. (https://aws.amazon.com/privacy/)	United States	To allow users to make payments in-game on the platform	Payment information
OneStore (https://m.onestore.co.kr/mobilepoc/web/clause/page.omp?termsCode=US010605)	South Korea	To allow users to make payments in-game on the platform	Payment information
Samsung Electronics Co., Ltd. (https://www.samsung.com/us/account/privacy-policy/)	South Korea	To allow users to make payments in-game on the platform	Payment information
Huawei Technologies Co. Ltd (https://www.huawei.com/en/privacy-policy)	PRC	To allow users to make payments in-game on the platform	Payment information
Discord Inc. (https://discord.com/privacy)	United States unless otherwise described in the service provider’s privacy policy	To display the leaderboard	Leaderboard highlights information
X Corp. (https://twitter.com/en/privacy)	United States unless otherwise described in the service provider’s privacy policy	To display the leaderboard	Leaderboard highlights information
Meta Platforms Inc. (https://www.facebook.com/privacy/policy/ and https://help.instagram.com/155833707900388)	United States unless otherwise described in the service provider’s privacy policy	To display the leaderboard	Leaderboard highlights information
YouTube, LLC (https://policies.google.com/privacy?hl=en)	United States unless otherwise described in the service provider’s privacy policy	To display the leaderboard	Leaderboard highlights information

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 countries or regions other than Ukraine, to the extent and for the purposes provided in 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, including sensitive personal information (denoted by *), 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 PASS Account Log-in information: user ID, user token, email address, username and country.
Internet or other electronic network activity information, such as your information regarding your use of the Service, including level, score, date and time stamps of actions, log-in and clickstream data and other Device Information as described in the main Privacy Policy. This information is collected directly from you and your device.
Commercial information about any transactions within the Website and Service such as the 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 the Website and Service. This information is collected directly from you.
Gameplay and combat information, such as user ID, game participation information, gameplay data (combat information), elimination reports information and battle history-related 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 information on social media. This information is collected directly from you and your device.
Leaderboard highlights information, such as ranking, level, user ID, username, team name, avatar, player login IP address, points, selected country or region for participation by player, value of in-game items collected, total number of eliminations for MVP, and whether you use QQ or WeChat. 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 the Service, 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 collect and disclose your personal information, including sensitive personal information, for the following purposes:

To provide you with the Website and Service, create and maintain your account, provide customer service, process payments, and deliver audio and text messages.
To allow you to participate in surveys.
To verify eligibility for participation in and to provide you with a Beta 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 provide you with a leaderboard.
To detect and prevent cheating in the Service.
To monitor the success of our advertising campaigns.
To improve our services, including the functionality of the Website and Service.
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, see Section 3 (How We Process Your Personal Information).

We disclose each of the categories of personal information that we collect as described in Section 4 (How We Store and Share 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.

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.

California Users Under 18

Any California residents under the age of eighteen (18) who have registered to use the Service and who have posted content or information on the Service can request that such information be removed from the Service by contacting us as specified in Section 8 (Contact). Such request must state that they personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the resident cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post, and archived copies of it may be stored by search engines and other parties that we do not control.

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.

Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:
- the categories of personal information about you that we collected;
- the categories of sources from which the personal information was collected;
- the business or commercial purposes 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 to Delete. Request we delete personal information we collected about you;
Request to Correct. Request we correct inaccurate personal information that we maintain about you;
Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted advertising or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects; and
Right to Non-Discrimination. 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 US State Laws.

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 as specified in Section 8 (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.

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 as set out in Section 8 (Contact).

What information do we need to be able to provide the Website and Service?	If you use the Website to sign up for the Service, we may collect certain information from you, such as your email address, device information (whether you use an iOS or Android device, and device model), IP address, and your gaming habits. If you register an account to use the Service then we will need some information from you to set this up. If you register for a LEVEL INFINITE PASS account, this includes a username and email address. We will generate an Open ID, which is an internal ID for your account. Depending on your use of the Service and the jurisdiction where you are based, you may also need to provide some additional information to help us set up your account. If you choose to set up your profile using a social media account, we collect information provided by your social media account service provider to automatically generate your profile, including name, user ID, profile picture and Open ID. To maintain the smooth operation of the Service (which includes activities such as from addressing bugs or malicious activity through to improving functionality) and to conduct data analytics, we will process customary device and network information (such as IP address, connection speed, device information and specifications, as well as app- and OS-generated identifiers).	More Information.
How will we use your information?	We use your information to set up your account, enable you to use the Service, enable interaction between users of the Service, save your progress, ensure the safe and secure operation of the Service, address bugs, conduct data analytics, optimise and improve the Service, protect users, and to comply with our legal obligations and enforce our legal rights.	More Information.
Who do we share your information with?	We use third parties and work with our affiliates to help us deliver the best possible experience (such as needed for analytics purposes and to send you in-Service notifications). 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 the Website and Service (i.e., to fulfil the purpose(s) described above). In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.	More Information.
Where do we process your information?	Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. Our servers for the Website and the Service are located in Singapore. We also have support, engineering and other teams who may support the Website and Service, including in Singapore and the People’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 or taking into account adequacy assessments.	More Information.
How long do we keep your information?	Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Service, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.	More Information.
How can I exercise my rights over my information?	Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.	More Information.
How will we notify you of changes?	Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.

Jurisdiction	Representative	Address	Contact details
EU	Proxima Beta Europe B.V.	Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands	dpo_uamo@proximabeta.com
UK	Image Frame Investment (UK) Limited	4th Floor, 80 Strand, London, United Kingdom WC2R 0RL	dpo_uamo@proximabeta.com
Republic of Korea	Kite Bird Korea Yuhan Hoesa	25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea	dpo_uamo@proximabeta.com
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	dpo_uamo@proximabeta.com
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-Service conduct, suspensions, investigations, civil or criminal complaints.	turkeydatarep_proximabeta@iptech-legal.com