Privacy Policy
Effective and Last Revised Date: 2023.04.23
- 1. Introduction
- 2. What Information Do We Collect
- 3. How We Use Your Information
- 4. How we Share Your Information
- 5. Cookies and Related Technologies
- 6. International Data Transfers
- 7. Retaining and Deleting Personal Information
- 8. Our Policy Concerning Children
- 9. Links and Third-Party Services
- 10. Security of Your Information
- 11. Your Privacy Rights
- 12. Amendments
- 13. Contact Us
- Appendix. SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC
Click HERE for the California Notice for California Residents
1. Introduction
KRAFTON (LIST of our affiliates) (“KRAFTON”, “we”, “our”, “company” or “us”) collect and process information about you (“you”, “user”, or “applicants”) when you visit, access, or use our websites (including our careers page or press site) (“Sites”). KRAFTON refers to KRAFTON, Inc. and its subsidiary and affiliated entities which provide or develop games and services under in different locations. This Privacy Policy(“Policy”) describes how we collect and use personal information about you during and after your relationship with us. By visiting our Sites or applying to our company you acknowledge the practices described in this Policy.
We will occasionally update this Policy. When we do, we will revise the effective date above. Your continued use of our website after such changes means you accept the Policy as revised. We encourage you to periodically review this Policy to stay informed about how we collect and process your personal information.
2. What Information Do We Collect
We will collect the following categories of information that may directly or indirectly identify or describe you or your device or information that may be reasonably capable of being associated with or reasonably linked to you or your device. The information you provide to us may differ depending on the circumstances. For example, these include:
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A)Identifiers, such as name, IP address, email address, phone number, date of birth, picture, gender, country of residence, language, nationality, or other information that you wrote in your resume, etc
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B)Internet or other electronic network activity information, such as browsing behavior while using our Services (i.e. device model, OS version, MAC address, device ID, etc.), etc.
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We use this data to operate and improve our Services. Some of this information is collected through our use of cookies and related online tools/technologies. See our “Cookies and Related Technologies” section below for more information.
3. How We Use Your Information
We use the collected information for a variety of purposes, primarily, to provide the Services to players like you and to improve the quality of our Services. These include:
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–To prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity;
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–To comply with and enforce legal requirements, agreements, and policies.
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–Achieve purposes for which we provide specific notice at the time of collection.
Most of the time, our processing of your personal information is necessary to respond to you or process your request. We may also process your information to comply with a relevant legal obligation. From time to time, we may ask for your consent to use your information for specific reasons. Where consent was provided and is required, you may withdraw your consent at any time by contacting us at the address provided in this Policy.
4. How We Share Your Information
We may share personal information with the following categories of parties and as otherwise described in this Policy or at the time of collection:
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–With our affiliates for the purposes described in this Policy, including to assess job applicants, progress the recruitment process, and respond to inquiries;
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–With our service providers who help us perform and deliver our services, including: cloud service provider, website management, hosting, and analytics; communications; form processing; information technology and security; job application systems providers; recruitment providers; and auditing;
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–With the appropriate authorities if we believe disclosure is necessary to prevent physical, financial, or other harm, injury, or loss, including to protect against fraud or credit risk;
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–With legal, governmental, or judicial authorities as instructed or required by those authorities and applicable laws, or in relation to a legal activity, such as in response to a subpoena or investigation of suspected illicit or illegal activities, or where we believe in good faith that users may be engaged in illicit or illegal activities, or where we are bound by contract or law to enable a network partner to comply with applicable laws; and
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–With necessary third parties in connection with, or during negotiations for, an acquisition, merger, asset sale, or other similar business transfer that involves all or substantially all of our assets or functions where personal information is transferred or shared as part of the business assets.
5. Cookies and Related Technologies
We use cookies, and other technologies to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes. Approved third parties may also set cookies and related technologies when you use our Services.
1) Cookies-
Cookies are small files downloaded to your computer (if your browser is enabled to accept cookies) to track movements within websites and to customize your experience within the website. Most Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of our websites may not function properly. We do not control cookies in third party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. Ads appearing on our websites may be delivered to you by third-party advertising companies. These companies may use information about your visits to our websites in order to provide advertisements to you and other sites about goods and services that may be of interest to you.
2) Website Analytics
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We use analytics services on our websites to allow us to record information on the use of this Site and to constantly improve our offering. This Site uses Google® Analytics, a web analysis services offered by Google Inc. (“Google”). We may use the following advertising functions of Google® Analytics and collect personal information as provided by Google, and you may withdraw your consent by deactivating such functions in Google’s advertising settings: Remarketing by using Google® Analytics; Google® Display Network Exposure Report; Google® Analytics Demographics and Interests Report; and Integrated service allowing the collection of data through Google® Analytics by using advertising cookies and anonymous IDs. More information about Google’s own privacy policy can be found at https://www.google.com/policies/privacy If you wish to opt-out from your information or data being used by Google Analytics, you may download the Google Analytics Opt-out Browser Add-on available here: https://tools.google.com/dlpage/gaoptout
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–Name of Chief Privacy Officer: Jinwon Choi
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–Email: privacy@krafton.com (Chief Privacy Officer) or DPO@pubg.com (Data Protection Officer)
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–Address: Yeoksam Center Field 231, Teheran-ro, Gangnam-gu, Seoul, Republic of Korea
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A)
International Data Transfer
If we transfer your data outside of the EEA to a country that is not recognized by the European Commission as ensuring an adequate level of data protection, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the latest standard contractual clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for personal data). You may ask for a copy of such appropriate measures by contacting us as set out in this Policy. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
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B)
Your Privacy Rights
You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.
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C)2. India
Representative in the EU
The GDPR(for EU Residents) requires a written designation of a representative in the EU by the controller or processor not based in the EU. Contact information and address of VeraSafe in the EU are as follows. Also to make such an inquiry about personal data processing, please contact VeraSafe using the consent form HERE.
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–Name of our Representatives: VeraSafe
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–Address: Keizersgracht 391 A, 1016 EJ Amsterdam
If you are a user in India, for any issues in relation to the collection and processing of your personal data, you may reach out to our Grievance Officer. The Grievance Officer will respond to your concerns and queries at the earliest and in compliance with applicable law.
Grievance Officer Information
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–privacy@krafton.com (Chief Privacy Officer)
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–Address: Yeoksam Center Field 231, Teheran-ro, Gangnam-gu, Seoul, Republic of Korea
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1)
Our Policy Concerning Underage Users
This Service is not intended for underage users. Thus, underage users should not use the Service unless parental consent is provided. We do not knowingly collect, use or share any personal information for those who are under 18 years of age without the consent and verification of the underage users’ parent or guardian, or unless permitted by law.
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2)
Sensitive Personal Information
We can collect your sensitive information(Proof ID number, etc.) when you apply to our company. We should collect or process your sensitive information under your consent.
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3)
International Data Transfer
For Indian users, your personal information will be stored and processed on services located in India and Singapore. However, we may transfer your data to other countries(i.e. Korea) and/or regions to process recruitment and/or to meet legal requirements. In the event of transfer to another country or region, we will take steps to ensure that your information receives the same level of protection as if it remained in India.
We may use your personal data (definition thereof shall follow the same under then-effective Japanese Act on the Protection of Personal Information) jointly with our affiliates as follows.
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Personal data used jointly
Any and all of your personal data that we collected in accordance with this Policy, whether directly, automatically or through third-parties, including but not limited to;
a. Identifiers, such as name, IP address, email address, phone number, date of birth, picture, gender, country of residence, language, nationality, or other information that you wrote in your resume
b. Internet or other electronic network activity information, such as browsing behavior while using our Services (i.e. device model, OS version, MAC address, device ID, etc.), etc. -
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Scope of joint users
KRAFTON, Inc. PUBG Japan K.K and our affiliates (LIST of our affiliates)
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Purpose of use by the joint users
For the purposes described specified in “3. How We Use Your Information” in this Policy.
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Party responsible for management of the personal data
Name of the party: KRAFTON, Inc. (More Information: LINK)
Address: 231, Teheran-ro, Gangnam-gu, Seoul, Republic of Korea 06142
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B)
International Data Transfer
If we transfer your data outside of Japan to a country that is not recognized by the Personal Information Protection Commission as establishing a personal information protection system recognized to have equivalent standards the same in Japan, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the reasonable standard measures following the requirements of Section 1 of Chapter 4 in Japanese APPI. You may ask for a copy of such appropriate measures by contacting us as set out in this Policy. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
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1)
Nevada
If you are a Nevada resident, we do not sell your personal information as that term is defined under state law, Nonetheless, if you are Nevada residents who purchased our goods from us, you may submit a request to record your preference to opt out for the future.
2)California
If you are a California resident, you may have additional rights as detailed below. Within the preceding 12 months, we have collected the following categories of personal information about you:
a. Identifiers, such as name, IP address, email address, phone number, date of birth, picture, gender, country of residence, language, nationality, or other information that you wrote in your resume
b. Internet or other electronic network activity information, such as browsing behavior while using our Services (i.e. device model, OS version, MAC address, device ID, etc.), etc.
We use your personal information listed above to operate or provide Services. For more details about using your personal information, you can check “3. How We Use Your Information”.
Within the preceding 12 months, we have disclosed for a business purpose your personal information to:a. Platform provider, cloud storage service provider. Also, we may provide service providers or third parties with certain personal information to provide or improve our services. We determine the retention period for each of the categories of personal information listed above based on:
a. any legal or regulatory requirements applicable to such information
b. provides and operate Services.
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Your California Privacy Rights
You may exercise the following rights at any point in time in connection with your personal information. To exercise such rights, please email us at privacy@krafton.com or visit our support page to request your rights.
Please note that at least your email address will be required to submit a request, and additional information may be required so we can verify you. If you exercise your rights via email, you must specify the right(s) you wish to exercise.
We will verify your identity and respond to your request within 45 calendar days. If necessary, we can take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, provided that we notify you to explain the reason for the delay.
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a.
Right to Know & Right to Access
You have the right to request the following information from us up to two times within a 12-month period:
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the categories of personal information that we have collected from you over the past 12 months, and the specific pieces of personal information we have collected from you;
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categories of the sources from which personal information was collected;
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business or commercial purposes for which personal information is collected;
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the categories of personal information that we have disclosed for a business purpose or sold during the past 12 months, and categories of third parties to whom the information was disclosed or sold (if applicable).
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b.
Right to Delete
You have the right to request that the personal information collected from you be deleted.
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c.
Right to Correct
You have the right to correct your personal information. You can edit your personal information to contact us through email for your rights.
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d.
Right to Non-Discrimination
You have the right not to be discriminated against for exercising these privacy rights.
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e.
Right to opt-out of Selling and Sharing
You have the right to opt-out of the selling and sharing of your personal information as defined by California law by requesting that your personal information not be sold or shared in any form. For targeted advertising you can control the sharing of your personal information for targeted advertising through our website. You can opt-out your advertising cookies through our cookie banner.
HOWEVER, WE HAVE NOT “SOLD” PERSONAL INFORMATION TO THIRD PARTIES AS THAT TERMS IS DEFINED BY THE CCPA WITHIN THE PAST 12 MONTHS. ALSO, WE HAVE NOT “SHARE” PERSONAL INFORMATION WITH THIRD PARTIES FOR THE CROSS-CONTEXT BEHAVIORAL ADVERTISING. -
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Rights for California Minors
Minors under the age of 16 have the right to request the deletion of and/or obtain information posted on websites such as forums or bulletin boards.
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g.
Shine the Light
You have the right to request the categories of the personal information that we disclosed to third parties for their direct marketing purposes during the past 12 months and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for their direct marketing purposes.
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h.
Limit Use and/or Disclosure of Sensitive Personal Information
You have the right to limit our use of their sensitive personal information. WE DO NOT USE YOUR SENSITIVE PERSONAL INFORMATION for purposes that require us to offer this limitation options. When we collect your sensitive personal information we will get a consent from you.
– Authorized Agent
You may designate another person or entity (“authorized agent”) to act on your behalf in connection with your request for rights that are guaranteed by the CCPA. An authorized agent is a natural person or business entity registered with the Secretary of State to conduct business in California that you have authorized to act of your behalf to make a request to know or to delete. In order to use an authorized agent for your request, we require that you provide signed permission to your agent. Your authorized agent can submit a request to know or delete by sending an email to privacy@krafton.com. If you contact us, we can offer you an authorized form for your agent to submit. The above requirement does not apply should your agent have power of attorney pursuant to Probate Code sections 4000 to 4465. Please note that we may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Under the CCPA, your agent is responsible for implementing and maintaining reasonable security procedures and practices to protect your information and use your personal information only for the purpose of fulfilling your request. If you have any questions about this Policy, or about exercising your rights described above, you can contact us by email at privacy@krafton.com..
3)Virginia
If you are a Virginia resident, you may have additional rights as detailed below. Please note that at least your email address will be required to submit a request, and additional information may be required so we can verify you. If you exercise your rights via email, you must specify the right(s) you wish to exercise.
– Privacy Rights for Virginia Residents
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a.
Right to Delete
You have the right to request that the personal information collected from you be deleted.
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b.
Right to Know, Right to Access & Data Portability
You have the right to request access to personal data collected from you. Subject to limitations imposed by law, you also have the right to obtain a copy of your personal data.
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c.
Right to Correct
You have the right to correct your personal information. You can edit your personal information to contact us through email for your rights.
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d.
Right to Appeal
If we decline to take any action in any request that you submit in connection with the rights described in the above sections, you may ask that we reconsider our response by sending an email from which you receive the decision. Requests to reconsider must be made within 45 days after receiving the appeal.
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e.
Right to Non-Discrimination
You have the right not to be discriminated against for exercising these privacy rights. If you have any questions about this Policy, or about exercising your rights described above, you can contact us by email at privacy@krafton.com.
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6. International Data Transfers
We recruit and make access to our Sites available to users, globally. Consequently, to provide our Sites and services and/or to meet legal requirements we may transfer your data to other countries and other regions outside of where you are located. By using our Sites and/or applying for a position, if applicable, you acknowledge that your personal information may be processed in a location outside of your own. For certain countries, we process the data in certain regions (as set out in more details below).
7. Retaining and Deleting Personal Information
We generally retain your personal information for the duration of your relationship with us and will delete it after the purpose of the collection is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using commercially reasonable technical measures in a way that the data cannot be reproduced.
8. Our Policy Concerning Children
We do not knowingly collect, use or share any personal information about children (age depending on the country where you reside) through our Sites. If you are a parent or guardian and you believe your child has provided us with personal information, you can contact us and request your child’s information to be deleted from our system.
9. Links and Third-Party Services
If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave the Site and go to the website you selected. Because we cannot control the activities of third parties, we do not hold any responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to our Sites, you should consult that site’s privacy policy before providing any personal information.
10. Security of Your Information
While no one can guarantee your personal information is completely secure at all times, we use administrative, organizational, technical, and physical safeguards to help protect the personal information we collect and process. Our security controls are designed to maintain data confidentiality, integrity, and give us appropriate access to your data. Among other things, we update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. We use professional third-party service providers, data centers to provide our Sites, and enter into confidentiality agreements with them where appropriate. Those service providers and data centers implement industry-standard measures to protect the security of the personal information we collect, such as SSL (Secure Socket Layers), firewalls, digital certificates, and encryption.
11. Your Privacy Rights
Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information. To make a request concerning your rights or if you have any other question, please contact us by sending an email to the address specified in the “Contact Us” section. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
12. Amendments
We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Games and Services. If we make material changes, we will post a prominent notice on our websites or in our Games and Services or give you other reasonable notice before any material changes take effect. All other changes are effective upon posting.
13. Contact Us
If you have any questions about this Policy, or your dealings with this Site, please contact us by using one of the following communication channels.
Appendix.
This portion of our Policy applies to residents of the jurisdictions indicated below. In the event of a conflict between the Policy and this section, this section supersedes and controls.
1. EEA, Switzerland, and the UKIf you are in the European Economic Area (EEA) or the UK, you may lodge a complaint with an applicable data protection authority for your country or region where an alleged infringement of applicable data protection law occurs.
Our representative in the EU is VeraSafe Netherlands BV, located at Keizersgracht 555, 1017 DR Amsterdam, Netherlands. To contact them, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.
Our representative in the UK is VeraSafe United Kingdom Ltd., located at 37 Albert Embankment, London SE1 7TL, United Kingdom. To contact them, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.
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