PRIVACY POLICY

GRAVITY GAME LINK PRIVACY & POLICY

Last Revised Date : December 12, 2022

Gravity Game Link and its affiliates are dedicated to protecting the privacy rights of our users (users or you). This Privacy Policy (Policy) explains how we collect, store, use and manage information, including personal information, that you provide or we collect in connection with our website, including https://gnjoy.id (Website) or Gravity Game Link games provided on mobile platforms (for example, iOS and Android) (collectively and services). Please note that the scope of this Policy is limited to information collected or received by Gravity Game Link through the use of our Service. Gravity Game Link is not responsible for the actions of third party persons or companies, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any links to these sites do not constitute our sponsors, or affiliations with, these persons or companies. By using the Service, you have agreed to this Policy and the processing of your data, including your personal information, in the manner provided in this Policy. If you do not agree to these terms, do not use the Service. If you have questions or concerns about our privacy policies or practices, please contact us at support.gnjoy.id.

Notwithstanding any provision herein, under any circumstance, the countries embargoed by the United States or the countries set forth on “the U.S. Treasury Department's list of Specially Designated Nationals or the U.S. Department of Commerce Denied Persons List or Entity List” shall be clearly excluded from the scope of any services

Collecting and Use of Information

The main purpose of Gravity Game Link in gathering and using information is to create your account, provide services to you, improve our services, contact you, conduct research and make reports for internal use. We store information on our servers located in Indonesia.

Gravity Game Link's Website

When you browse the Gravity Game Link Website, your computer's operating system, Internet Protocol (IP) address, access time, browser type and language and website address references can be recorded automatically. We may use this information to monitor, develop and analyze the use of our Service. In addition, we may ask you to send and we can process data that is personal to you, including but not limited to name, profile photo, gender, age or date of birth, links to your profile on social networking sites and other third party sites, user names and e-mail addresses. We may use this information to create user profiles and provide services for you. We can use your email address to notify you about company news and promotions. Your gender and date of birth can be used to analyze user trends and target certain promotions. If you no longer wish to receive this type of promotional material, you can choose not to receive it at any time by sending us an email at support.gnjoy.id.

Social Media

Our website includes Social Media Features, such as the Facebook button and Widgets, such as the Share button or an interactive mini program running on our website. These features can collect your IP address, which pages you visit on our site, and can set cookies to enable the Feature to function properly. Social Media Features and Widgets are hosted by third parties or hosted directly on our Site. Your interaction with these features is regulated by the privacy policy of the company that provides it.

iOS and Android Platforms

When you use Gravity Game Link games or applications on a cellular platform, we can collect and record certain information such as your unique device ID (persistent / non-persistent), hardware type, media access control, MAC address, IMEI's international cellular equipment identity, version of your operating system, your device name, your email address (if you are already connected to Facebook or Google+), and your location (based on your Internet Protocol IP address). This information is useful for us to solve problems and help us understand usage trends.
We may collect your location-based information for the purpose of providing you with the right version of the application. We will not share this information with any third parties. If you no longer want us to track or use this information, you can turn it off at the device level. Please note, the application may not function properly if we do not know where you are from (Country base). In addition, we create unique user IDs to track your use of our services. This unique user ID is stored in connection with your profile information to track the Gravity Game Link's game you are playing.

Facebook Connect, Apple Game Center and Google Play Game Services

You can log in to our site using social media services such as Facebook Connect, Google Play Game Services, Apple Game Center, or Open ID providers. This service will authenticate your identity and give you the option to share certain personal information with us such as your profile, gender, and country. Services such as Facebook Connect give you the option to send information about your activities on this website to your profile page to share with others in your network. We may collect and record information through Social Media Services in accordance with the policies and conditions of the Social Media Services.

The information we collect when you connect your user account to Social Media Services may include: (1) Profile Name, (2) User ID Number and / or User Name for your SN Service, (3) Address, City, State and Country, (4) Gender.

Invite A Friend

Gravity Game Link can offer you the opportunity to invite your contacts from Social Media Services (such as your Facebook friends) so that these contacts can be found in the Gravity Game Link game and / or you can invite them to join you in the Gravity Game Link game. The contact information will only be used for the purpose of sending communications to the recipient.

Customer Service

We can collect your email address when you contact our customer service or customer support, and we can use that email address to contact you about your gaming experience with the game Gravity Game Link and inform you about company news and promotions. If you no longer wish to receive certain e-mail notifications, you can opt out at any time by sending us an e-mail at support.gnjoy.id.

Push Notifications

We sometimes send you push notifications through our mobile application to send you game updates, highest score information, and other service-related notifications that may be important to you. You can choose not to receive this type of communication at any time by turning it off at the device level through your settings.

Game Data Collection

Every time you play our game, we collect data about all of your interactions with the game and with other players in the game through the server log file. This information can be associated with your Player ID, IP Address or device ID for the purpose of providing you with our Services and improving it.

Tracking Technologies

We and our marketing and outsourcing partners, affiliates or analytic service providers use technologies such as cookies, beacons, scripts and tags to identify a user's computer / device and to remember things about your visit, such as your preferences or user name and password. The information contained in cookies can be linked to your personal information, such as your user ID, for purposes such as improving the quality of our Services, adjust recommendations to your interests, and making the Service easier to use. You can disable cookies at any time, but you might not be able to access or use Service features.

We may display advertisements that are served by third parties who send cookies to your computer / device so that the content you access and the ads you see can be tracked. Because third-party advertising companies associate your computer / device with a number, they will be able to recognize your computer / device every time they send you an ad. These advertisers can use information about your visit to our Services and third-party sites and applications to measure ad performance and to provide advertisements about goods and services that interest you. This policy does not apply to, and we are not responsible for data collection practices from these third-party advertisers, and we encourage you to check their privacy policies to learn more about the use of cookies and other technologies.

Cellular Analysis

We use cellular analytics software to enable us to better understand the functions of our Cellular Software on your device. This software can record information such as how often you use the application, events that occur in the application, aggregate usage, performance data, and where the application was downloaded. We do not link the information we store in analytic software to any personal information that you send in the mobile application.

Third Party Services

Our services can contain third-party tracking devices from our service providers, for example including Google Analytics and MobileAppTracking by Tune. These third parties may use cookies, APIs and SDKs on our services to enable them to collect and analyze user information on our behalf. Third parties may have access to information such as your device identifier, MAC address, IMEI, local (specific location where certain languages are used), geo-location information, and IP addresses for the purpose of providing their services under the privacy of each policy. Our privacy policy does not cover the use of tracking devices from third parties. We do not have access to or control over these third parties.

Advertisement Network

We may display advertisements in our services. Advertisers can collect and use information about you, such as your Service session activity, device identifier, MAC address, IMEI, geo-location information, and IP address. They can use this information to provide advertisements that are of interest to you. In addition, you can see our games advertised on other services. After clicking on one of these advertisements and installing our game, you will become a user of our service. To verify installation, device identifiers can be shared with advertisers.

How We Use the Information:

We use the information collected through our Services for the purposes described in this Policy or disclosed to you in connection with our Services. For example, we can use your information to:

Create a game account and allow users to play our game;
Identify and suggest connections with other Gravity Game Link users;
Understand your preferences to enhance your experience and pleasure using our services;
Respond to your comments and questions and provide customer service;
Provide and deliver the products and services you have requested;
Send you related information, including confirmations, invoices, technical notifications, updates, security alerts, and support and administration messages;
Communicate with you about promotions, reward, upcoming events, and other news about products and services;
Enable you to communicate with other users; and
Link or combine it with other information that we get from third parties, to help understand your preferences and provide you with better service.

Disclosure of Your Information

Gravity Game Link does not share your personal information except as agreed by you or as explained below: With your consent, for example, when you agree to us sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies. If you no longer want to allow us to share your information with third parties, please contact us at support.gnjoy.id.

We may release your information as permitted by law, such as to comply with a subpoena, or when we believe that the release is appropriate to comply with the law; fraud investigation, respond to government requests, enforce or apply our rights; or to protect of our company, our users and others rights, property or safety. This includes exchanging information with other companies and organizations for fraud protection.

Gravity Game Link may share your information regarding mergers, sales of our assets, or financing or acquisition of all or part of our business with other companies. You will be notified by email and / or notice on our site about any changes in the ownership or user of your personal information. We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors and other third parties.

Policy Changes

We may update this privacy policy to reflect changes to our information practices. We encourage you to periodically review this page for the latest information about our privacy practices.

Security

Gravity Game Link takes reasonable action to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store information collected on the Service in a secure operating environment that is not publicly available, we cannot guarantee the absolute security of that information during transmission or storage on our system. Furthermore, while we strive to ensure the integrity and security of our networks and systems, we cannot guarantee that our security measures will prevent third-party hackers from illegally gaining access to this information. We do not guarantee or represent that your information will be protected against loss, misuse, or alteration by third parties. However, there are no methods of transmitting over the Internet, or methods of electronic storage, that are 100% safe. Therefore, we cannot guarantee absolute safety.

Access to Personal Information

If your personal information changes, or if you no longer want our services, you can correct, update, or delete inaccuracies by making changes in your account settings or by contacting us at support.gnjoy.id. We will respond to your access request within 30 days.

Our Policy About Children

We do not intentionally collect or request personal information from anyone under the age of 13 or intentionally allow that person to use our Services. If you are under 13, do not send information about yourself to us, including your name, address, telephone number or email address. No one under the age of 13 can provide any personal information. If we find out that we have collected personal information from a child under 13, we will delete that information as soon as possible. If you believe that we may have information from or about a child under the age of 13, please contact us at support.gnjoy.id.

Marketing Preference

You can choose not to receive promotional emails from us by sending us an email at support.gnjoy.id. If you choose not to receive, we can still send you non-promotional emails, such as emails about your account or our ongoing business relationship.

If you have questions about this Policy, please contact us at support.gnjoy.id.

※SPECIAL PROVISION : “Privacy Notice for California Residents”

Privacy Notice for California Residents

Effective date: July 15, 2022

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who use the Service and reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Protecting your privacy is important to Gravity Game Link and its subsidiaries and affiliates (“Gravity,” “we,” “our,” or “us”) because we know how important it is to you. This Privacy Notice describes the information that we collect through websites that we operate (each, a “Site”), our game publisher networks, crowd-sourcing service, and platforms (each, a “Network”), any mobile and web application of ours (each, an “App”), and chat rooms, blogs, web forums, messaging boards, or other public forums in our Apps and Sites (each, a “Forum”); how we use, disclose, and protect your information; and the choices you can make regarding your information. The Sites, Networks, Apps, and Forums are referred to herein, collectively, as the “Service.”

Please check below and put information how GGL deals with the information

1. INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, through your use of the Service, we have collected the following categories of personal information within the last twelve (12) months:

Category	Examples	Collected
Identifiers	Online identifier, Internet Protocol address, email address, account name	YES
Personal information categories listed in Cal. Civ. Code § 1798.80€	A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information	NO
Protected classification characteristics under California or federal law	Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)	NO
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	YES
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data	NO
Internet or other electronic network activity information	Browsing history, search history, and information on a consumer’s interaction with an Internet Web site, application, or advertisement	NO
Geolocation data	Physical location or movements	NO
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	NO
Professional or employment-related information	Current or past job history or performance evaluations	NO
Non-public education information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	NO
Inferences drawn from any of the information identified above	Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	NO

Personal information does not include:

Publicly available information from government records;
De-identified or aggregated consumer information;
Information excluded from CCPA’s scope, like personal information protected by other certain sector-specific federal or California statutes.

2. HOW WE COLLECT PERSONAL INFORMATION
We obtain the categories of personal information listed above from the following categories of sources:

Directly From You: The information you provide while using the Service.
DIndirectly From You: We collect certain technical information, like the Internet Protocol address, when you access and use our Service.
Collected and/or Received From Third Parties: We may collect your data from third parties, such as when processing your purchases through our Sites or Apps or when you access our Service through a social networking service (“SNS”).
Collected Through Mobile Devices: When you use our Apps on your mobile telephone or other mobile device (“Mobile Device”), you are authorizing us to collect, store, use, and/or share, in addition to the information described above, the Mobile Device type; mobile carrier; platform version; navigation, interaction, and engagement information regarding our users; and other information you choose to provide to us. Also, we receive and store information you provide when you sign up to have Short Message Service (“SMS”) notifications sent directly to your Mobile Device.

3. HOW WE USE PERSONAL INFORMATION
We may use the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information;.
To provide, support, personalize, and develop our products and services for and through our Service;
To create, maintain and service accounts;
To provide customer service;
To process your requests and payments and fulfill orders and transactions;
To verify consumer information;
To personalize your Site, App, and Forum experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Service and via email or text (with your consent, where required by law);
To provide advertising and marketing services;
To provide analytic services;
To detect and respond to security incidents;
To improve our Service;
For testing, research, analysis, and product development;
For auditing related to a current interaction with the user and concurrent transactions, including but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
As described to you when collecting your personal information or as otherwise set forth in the CCPA;
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Gravity’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Gravity about our Service’s users is among the assets transfers.

Gravity will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4. SHARING PERSONAL INFORMATION
Gravity may disclose your personal information to a third party for a business purpose. When we disclose your personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep your personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:	Identifiers
Category D:	Commercial information

We disclose your personal information for a business purpose to the following categories of third parties:

Our affiliates;
Our Partners
Service providers;
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

5. DATA SECURITY
We have implemented measures designed to secure and safeguard your personal information from accidental loss and from unauthorized access and disclosure. We maintain physical, electronic, and managerial procedures to limit access to your non-public personal information.
Unfortunately, transmission of information via the internet is not completely secure.Although we take reasonable precautions to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our Services or other electronic means. Any electronic transmission of personal information is at your own risk.

6. YOUR RIGHTS AND CHOICES
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you;
The categories of sources for the personal information we collected about you;
Our business or commercial purpose for collecting that personal information;
The categories of third parties with whom we share that personal information;
The specific pieces of personal information we collected about you (also called a data portability request);
The specific pieces of personal information we collected about you (also called a data portability request);
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

sales, identifying the personal information categories that each category of recipients purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation;
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Visiting labyrinthnft.gnjoy.id
Emailing us at privacy@gnjoy.id

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will use only personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

7. NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or service;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services;
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

8. CHANGES TO OUR PRIVACY NOTICE
Gravity reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this privacy notice, we will update the Privacy Notice’s effective date, and notify you via email at the last email address that you provided us and post the updated notice on the Sites. Your continued use of our Service following the posting of changes constitutes your acceptance of such changes.

9. CONTACT INFORMATION
If you have any questions or comments about this Privacy Notice, the ways in which Gravity collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Visiting labyrinthnft.gnjoy.id
Emailing us at privacy@gnjoy.id

Gravity Game Link

PRIVACY POLICY (For EU and UK Residents)

Last Revised Date :December 12, 2022

1. Introduction
We take privacy seriously, and we are committed to protecting personal data (the “Personal Data”) of our users (“you” or “User”) who reside in the territory of the European Union (EU) which includes the European Union member states and Iceland, Liechtenstein, and Norway. This policy also covers our users who reside within the United Kingdom.

This Privacy Policy (the "Policy”) is based on the principles set forth under the General Data Protection Regulation (GDPR) (and any other applicable law mandating data protection/GDPR) and describes the full scope of purposes and reasons for collecting and processing of Personal Data. This privacy policy also determines and limits what Personal Data we collect and how we use it (several sections below), how long we store it (is covered in each section devoted to the specific data), who has access to it, and what rights and other control mechanisms are available to you as a User.

This Policy applies where we are acting as a data controller concerning your data and is limited to data collected or received by us through your use of our Services (defined hereinafter).

2. Who We Are
Gravity Game Link. ("Controller"), with Controller’s affiliates and independent contractors (“Co-Providers”, collectively with Controller, "us," "our," or, "we"), provide mobile game named Ragnarok Labyrinth NFT (“Game”) and related services, including, without limitation, online communities for Game or social network services offered by us via labyrinthnft.gnjoy.id(collectively, our “Service(s)”). For clarity, the specific list of Controller’s affiliates and Co Providers are as followed.

Name	Address	Role
Gravity Game Link.	Jl. Joglo Raya No.88, E Lt. 4 RT 007 RW 03, Kel Joglo, Kec Kembangan, Kota Adm Jakarta Barat,11640, Indonesia.	Developer and publisher

The Services for our Game includes Sites, without limitation, such as online communities for Game or social network services offered by us via labyrinthnft.gnjoy.id. The specific list of our Sites are as followed.

Name	Address
Ragnarok Labyrinth	labyrinthnft.gnjoy.id.
Customer support page	support.gnjoy.id/hc/en-us

The Personal Data is processed by:

Company Name: Gravity Game Link.

Official Address: Jl. Joglo Raya No.88, E Lt. 4 RT 007 RW 03, Kel Joglo, Kec Kembangan, Kota Adm Jakarta Barat,11640, Indonesia.

Phone: +622129022069

Contact Email: privacy@gnjoy.id

The EU Representative of Controller under EU GDPR can be reached at:

Company Name: The DPO Centre

Official Address: Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2

Phone: +353 1 631 9460

Contact Email: eurep@gravitygame.id"

Website: www.dpocentre.com/contact-us

The UK Representative of Controller under UK GDPR can be reached at:

Company Name:The DPO Centre Ltd.

COfficial Address: 50 Liverpool Street, London, EC2M 7PY

Company Name: The DPO Centre Ltd.

Phone: +44 (0) 203 797 6340

Contact Email: ukrep@gravitygame.id

Website: www.dpocentre.com/contact-us

3. Processing of Personal Data
We process your Personal Data when they are strictly necessary for the following purposes:

3.1 Performance of our Service

to provide our Services to Users namely: registration (creation) and operation of Game account, providing access to the Game account, formation and performance of the agreement with us on using the Services, providing the Game, the Services and Game access to Users, sending, processing of and responding to support tickets along with other communications with us, payment acceptance;
to enhance the security and safety of your Game accounts;
to communicate with you about transactions made by you while using our Services or Game, as well as to send you notifications related to your account security such as notifications about password recovery requests, editing security settings, changing of e-mail or profile settings and similar;
to send you information about updates in our Services or Game, about features on our Sites, about upcoming events (online and offline) and other information related to our Services or Game (in case you have not unsubscribed);
to inform you about changes in our policies and legal documents;
to communicate with you to resolve any problem you faced while using our Services or Game;
to inform you about our activities (in case you have not unsubscribed); for developing new tools, products or services for you;
to provide support, as well as technical support, including, but not limited to, Game and Services updates, product patches and fixes and other similar communications;
to restore access to the User’s account, Services and/or to the Game;
to restore lost payments made by the User
to improve our Services and Game, as well as while requesting your feedback about our Services and Game;
to provide you with information, Services, and the Game available at or intended for the territory where you are;
to send notifications or communications related to access to Our Services and/or the

Game, password restoring or otherwise restoring access to the User’s account. You can disable this feature at any time, though you will be unable to use such features.

For these purposes, we process, if any, the following Personal Data:

Compulsory Data that is processed in all events:

º User’s ID in the social network that is used for registration at Game (if applicable)

º correspondence with User, including support tickets along with other communications;

º IP address and other online identifiers of User’s devices and applications

Compulsory Data is required for us to provide Services and the Game to Users and perform other obligations under the agreements concluded with Users. Request for erasing of such data may result in your inability of using our Services as set forth in below.

Compulsory Data may be collected through, namely:

through registration with Services and/or with the Game;
while contacting us via e-mail, phone or mailing address of ours;
while contacting our support team or otherwise;
while using the forum, chats related to Services and/or the Game;
while using Services and/or the Game otherwise (including information you provide to when participating in competitions, contests, and tournaments or responding to surveys, e.g. your contact details);

We also process anonymous data to analyze and produce statistics related to the habits, usage patterns, as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. Anonymous data, may be shared with third parties.

If we find that you provided incorrect or inaccurate Personal Data, it may restrict (ban) your Game account until you amend it.

3.2 Payment
When the User tops up his or her Game account or makes payments via application market such as Google Play or App Store (the “App Markets”), we and the App Markets that is chosen by the User to process the payment may, if any, exchange with the following Data:

user ID from our billing system
user ID in the payment system
payment (transaction/order) ID
date and time of payment (transaction/order)
amount of payment (transaction/order)
the currency of payment (transaction/order)

When the User use credit cards for payment purposes, the Data, if any, required by App Markets are:

name of the cardholder;
masked card number - 6 symbols and last 4 digits;
country code (if applicable);
address (if applicable).

Such Data regarding credit card payment as mentioned is provided by the User directly to the payment systems under the terms of use of such system that the system may require Users to enter before processing the payment. We do not process such Data.

3.3 Promotion
We process, if any, Personal Data on the lawful bases of consent and legitimate interests pursued by us or a third party (e.g., the interests of other customers of ours), except where such interests are overridden by your prevailing data protection rights and if you have withdrawn your consent, to send promotional or marketing information and news about the planned contests, promotions and similar events, news about our Services and the Game.

If you do not wish to receive such information, you can unsubscribe from receipt of such information following the instructions as described in the corresponding messages or Game account interface.

We also process Personal Data on the same lawful basis in order to manage Users’ relationships and organization, follow-up, communication, subscription and invitations relating to competitions, events or game tournaments organized or supported by us (for example, communication with you when you take part in online or offline competitions, events or game tournaments organized or supported by us or arrange your travel, receipt of gifts and awards, to which you may be entitled as a result of winning in online or offline competitions or events, etc.).

The scope and purpose of the processing of your Personal Data, among other conditions for the processing, is specified in this Policy. We will notify you about any changes in our Policy.

Process of Non-Personal Data for improvement and development

To provide quality Services and to justify your expectations of Our Services and/or Game, we collect, if any, anonymous data:

name and version of the operating system,
the size of RAM
the size of available disk space
parameters of the network channel and internet connection such as network bandwidth and delay from User’s mobile devices to our servers, traceroute information between your mobile devices and our servers, etc.
other data that is mentioned in the Technical requirements to the Game

We collect information about your Game' preferences, progress in Game, playtime, as well as information about device settings, unique device identifiers, and crash data. We process and store such data also to evaluate development plans, provide updates to the Services and Game, bug-fixing.

Such information, is stored for the validity period of relevant agreements with us and 1 year after the termination of such agreements unless there is a legitimate reason for a longer processing.

Be also aware, that for the purpose of organization of game process, we collect information about your in-game activities, logs, and data on in-game transactions. Such data also used for Game violations detections (as well as Sites violations) to prevent or punish for cheating and unfair gaming behavior. This data is used for detection, investigation, prevention and, where applicable, and stored only for the minimum amount of time needed for this purpose. If the data indicates that a violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such violations. Also be aware that enjoying a certain User’s rights shall be in balance with rights and interests of other Users and should not affect the rights and freedoms of other parties.

3.4 Prevention of illegal behavior
We process your Personal Data on the lawful basis of compliance with legal obligations that we are subject to in order:

to prevent the illegal use of our Services and the Game if there is reason to believe that there is a risk to security of Our Servers (i.e. blocking of concurrent IP addresses).

For this purpose, the Data processed is:

- IP address and other online identifiers,

- browser or device identifiers,

- operating system,

- crash data.

to prevent illegal user’s access

For this purpose, the Data processed is:

the organization of the game process,
information about your in-game character activities, logs, and data on in-game transactions,
Game data and commands the so-called log files (information on the actions made by the character in the Game generated by the software, fixed in symbolic non-personal form),
the content of in-game chats (correspondence).

We use this data for decisions to ban a Game account or user’s character, according to the rules of the relevant Game.

In the event of litigation between the User and us or in case we receive a request from competent authority, such data can be combined with the personal information you provide and are stored during the period of resolution of the dispute.

4. Security Measures
Our endeavors to implement technical and organizational measures to protect your Personal Data against accidental or unlawful destruction, alteration or loss, unauthorized disclosure, or access. We, affiliates and third parties authorized to access the Personal Data, are required to give the undertaking to maintain such confidentiality and secrecy.

Among other measures, any information sent to us is encrypted (scrambled) using high qualified technology. This is industry-standard encryption technology that protects your data while being sent over the Internet from being intercepted and misused by third parties.

We have put in place, and regularly reviews and updates, appropriate physical, electronic, and managerial procedures to keep the data safe and help prevent unauthorized access, maintain data security and correctly use the information collected.

Should we become aware of a data breach we will take all relevant actions and steps necessary to rectify the breach. We will also notify the relevant supervisory authority and individuals (if required under the GDPR and other applicable data protection laws) and work with other parties as required to ensure any breaches are remedied and there is no other compromise of personal data.

5. Sharing of User’s information We do not transfer your data to anyone, except for those specified in this Policy or as provided by the rules into force. This is related to the provision of Our Services and performance of contracts you have concluded with us. If such transfer to third parties is related to any other purpose, we will notify you of such transfer.

We do not sell your personal information and does not receive benefits from any treatment of your data. We do not use your data for advertising or promotion of products and services of third parties.

(1) Regarding Payment systems, we share your Personal Data such as:
Email address, IP address, information about in-game purchases, and other information you provide to us for the purpose of fulfilling your purchase. The list of payment methods (payment systems, payment agents) that may be used by the User for payments and with which we may share your data are described at our Sites. The specific list of the entities who access the Personal Data to process the payment, the place where the transferred Personal Data is stored and the relevant contract name based on which the Personal Data is transferred are as followed.

Name	Data Storage Place	Transferred Data	Relevant Contact
Google Play	Dublin, Ireland	Information about in-game purchases	policies.google.com/privacy?hl=en
App Store	Aabenraa, Denmark	Information about in-game purchases	support.apple.com/en-ie/HT210584

(2) With data storage partners, we share your Personal Data
Some of the information is stored using third-party data storage services. We provide personal information to our affiliates and other trusted businesses or persons to process it for us, in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. The specific list of the entities whose information storage service is used for the custody of Personal Data, the place where the transferred Personal Data is stored and the relevant contract name based on which the Personal Data is transferred are as followed.

Name	Data Storage Place	Transferred Data	Relevant Contact
Naver Cloud	Seoul, Korea	User ID, Payment history, Item logs	www.ncloud.com/policy/infou/infou?language=en-US

The data is stored separately. Your data may be combined with other data collected by us in exceptional cases, for example, in case of a violation by users of the agreement with us or the rules of the game, the availability of a dispute between us and the User, conduct of financial control and accounting, etc. As for the detecting violations, be aware that we use anti-cheating tools that collect information about the processes in use while you are accessing Game.

The User can modify and/or erase the data provided to them, except for those specified in this section as unalterable. The user may edit his personal information having access to his private account. All changes are logged.

(3) For publicly available information
Our Sites may also have, if any, message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum, or chat area, please be aware that the information is being made publicly available on-line; therefore, you are doing so at your own risk. If your personal information is posted on one of our community forums and you want to remove such information, please inform us with request to its removal.

(4) With Anti-cheat and anti-fraud companies,
We share the information required for our detection, investigation, and prevention of cheating in the Game and violations of agreements related to the Game only for the purposes of detection, investigation, and prevention of cheating in the Game.

(5) When our control is changed
We may share your data as part of our company’s sale, merger or change in control, or preparation for any of these events. Any entity which buys us, or part of our business will have the right to continue using your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

6. Retaining and Deleting Personal Data
We retain, if any, your Personal Data only for the period of time as necessary to achieve the particular purpose for which the information was processed.Typically, without your request to erase Personal Data and also without legitimate reason to keep it longer, after the termination of our relationship, we retain your information for 1 month after deregistration of your Game Account or for the duration described in the table below:

Personal Data Retained	Retention Period
Data necessary for performance of the agreement or cancellation of subscription Records of payment Tax and accounting records Records of electronic financial transaction	5 years
Records of a customer complaint or dispute resolution Records that Game account or character was banned based on the violation.	3 years
Records of correspondence with User for statistics purposes; to deliver, develop and improve our Service and the Game; to support Users in using the Services and the Game; to ensure security and confidentiality of the User’s account and data; to restore access to the User’s account, Services and/or to the Game; to restore lost payments made by the User. Record of User’s Game' preferences, progress in Game, playtime, as well as information about device settings, unique device identifiers and crash data.	3 years
Record of in-game character activities, logs, and data on in-game transactions, log-files and in-game chats. Records of misuse by users of Game or Services	3 years
Computer communication or internet log-in records of computer communication or facts about an internet user’s utilization of telecommunication service	3 years
Record of IP address and other online identifiers	3 years
Log-files and chat in case of dispute with the User	The duration of the dispute

For the clarity, we retain your information insofar as such information will be processed solely for archiving purpose in the compliance with our legal obligation or statistical purposes, subject to appropriate safeguards, in accordance with the data protection laws, for your rights and freedoms. The appropriate safeguards shall ensure that technical and organizational measures are in place to ensure respect for the principle of data minimization.

7. Our Policy Concerning Children
You must be at least 13 years of age to use our services and we do not knowingly collect any personal information from children under the age of 13 years old. If a child under 13 years old and would like to make use of our services (i.e. download and play the game we are offering) parental/legal guardian approval (i.e. consent) is required. We will take reasonable efforts to ensure we gain approval from a parent/legal guardian by taking the below steps:

1. When the app is downloaded those who are under 13 years old will need to provide a parents/legal guardians email address where required

2. Once sent to us we will send an email asking approval (i.e. parental/legal guardian consent) for someone under 13 to use our services

3. Once we receive approval from a parent/legal guardian for those under 13 years old, they can start making use of our services

4. If a parent/legal guardian rejects approval our services cannot be used ios

Gravity Game Link. is not responsible for those who have falsely claimed to have gained parental/legal guardian consent. If we discover a child under 13 years old has not gained parental/legal guardian consent, we will take all reasonable measures to delete their information from our systems which may also result in banning them from using our services again. You can contact us at privacy@gnjoy.id to inform us if you suspect someone under 13 years old is using our services and has not gained parental/legal guardian consent at any time.

8. Your Privacy Rights
(1) Right to Access
You are entitled to confirmation as to whether or not we process your Personal Data and, where we do, access to the Personal Data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Data concerned, and the recipients of the Personal Data. We will supply you a copy of your Personal Data. You can access your Personal Data by logging into your Game account or contacting us using our details listed above.

(2) Right to Rectification
You are entitled to have any inaccurate Personal Data about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about you completed. You may change or update the profile information by logging into your Game account or by contacting us using our details listed above.

(3) Right to Erasure
In some circumstances, you are entitled to the erasure of your Personal Data without undue delay. Those circumstances include: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing; (iii) you object to the processing; (iv) the Personal Data must be erased to comply with a legal obligation and (v) the Personal Data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: (a) for exercising the right of freedom of expression and information; (b) for compliance with a legal obligation; (c) for public interest or (d) for the establishment, exercise or defense of legal claims.

If you choose to terminate or delete your Game account, we will immediately delete your Game account information.

If a User requests the erase of the Personal Data, while a prior request (s) from that User is still being processed, such data can be erased only when the User has recalled/canceled all previous requests.

You may request the erasure of your information by visiting the Sites or by contacting us using our details listed above.

(4) Right to Restrict Processing
In some circumstances, you are entitled to restrict the processing of your Personal Data. Those circumstances are: (i) you contest the accuracy of the Personal Data; (ii) processing is unlawful, but you oppose erasure; (iii) we no longer need the Personal Data for the purposes of our processing, but you require Personal Data for the establishment, exercise or defense of legal claims; and (iv) during the verification of the prevalence of the legitimate interest that we pursue regarding the Personal Data processing on yours. Where processing has been restricted on this basis, we may continue to store your Personal Data. However, we will only otherwise process it: (a) with your consent; (b) for the establishment, exercise or defense of legal claims; (c) for the protection of the rights of another natural or legal person; or (d) for reasons of important public interest.

You may request the restriction of the processing of your information by visiting the Sites or by contacting us.

(5) Right to Object to Processing
You have the right to object to our processing of your Personal Data, at any time, on grounds relating to your particular situation, but only to the extent that the lawful basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You may object to the processing of your information by visiting the Sites or by contacting us using our details listed above.

(6) Right to Object to Processing for Direct Marketing Purposes
You are entitled to object to our processing of your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your Personal Data for this purpose.

You may object to the processing of your information for direct marketing purposes by visiting the Sites or by contacting us using our details listed above.

(7) Right to Object to Processing for Statistical Purposes
You have the right to object to our processing of your Personal Data for statistical purposes. We do statistical processing for analyzing game data for analysis and optimization of the service and advertising campaigns which can include the user’s device or IP information.

You may object to the processing of your information for statistical purposes by visiting the Sites or by contacting us using our details listed above.

(8) Right to Data Portability
To the extent that the lawful basis for our processing of your Personal Data is:

consent; or
that the processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract, and such processing is carried out by automated means, and you have the right to receive your Personal Data from us in a structured, commonly used and machine-readable format and the right to have your Personal Data transmitted to another controller.

You may request to receive your information by visiting the Sites or by contacting us at using our details listed above.

(9) Right to Complain to a Supervisory Authority
If you consider that our processing of your Personal Data infringes data protection laws, you are entitled to file a complaint with a supervisory authority responsible for data protection.

You can find more details of the supervisory authority in your country by visiting

ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

For the UK:ico.org.uk/make-a-complaint

(10) Right to Withdraw Consent
To the extent that the lawful basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may withdraw your consent at any time in the Game setting or contacting us at using our details listed above.

You may also exercise any of your rights concerning your personal data by written notice to us at using our details listed above.

(11) The right to not be subject to automated decision-making
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

9. Change/Update to Privacy Policy
We may amend, at our discretion, any portion of this Privacy Policy at any time by posting or displaying the amended Privacy Policy within and/or on the Sites. We request your reading confirmation for each of these amendments. Except as otherwise stated, any such amendments will be automatically effective after they are initially posted. We will notify you about any significant changes in our Policy. This policy was last updated on July 15, 2022

10. Links
(The Service may contain links to other websites. The fact that the Service links to a website or presents a banner ad or other type of advertisement does not mean that we endorse or authorize that third party, nor is it a representation of our affiliation with that third party. We are in no way responsible for the privacy policies of these other websites to which you choose to access from the Services. It is your responsibility to read the privacy policies of these other websites when exiting the Services.

11. Questions
If you have any questions regarding our Privacy Policy and/or practices, please email us using our details listed above.