Privacy Policy

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

Please note that this privacy policy (“Privacy Policy”) applies to the game Insterra (“Game”) and the main website for the Game (“Website”, which together comprise the “Game Services”). If you use any other products or services, please refer to the privacy policy Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) applies to the game Insterra (“Game”) and the main website for the Game (“Website”, which together comprise the “Game Services”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

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

For the purpose of data protection laws, the data controller of your personal information in relation to the Game Services is Insterra.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘MoreInformation’.

What information do we need to be able to provide the Game Services?

In relation to the Website:

• If you register to receive updates on the development of the Game, then you will need to provide your email address, among other information.
• To monitor the performance of the Website and perform statistics on page view and user view of the Website, we will process customary device and network information (such as IP address).
• If you register for our Game playtests, then we may process your region, date of birth, Discord ID or Steam ID, email address, and other information you provide on our survey questionnaire (such as your gaming habits, gaming preferences and device specifications).

In relation to the Game:

• If you register an account for or log in to use the Game  (via LEVEL INFINITE PASS), we will need some information from you to set this up. This includes your email address, password, user ID, nickname, user token, and country. 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, such as user ID, nickname, profile picture, user token and Open ID.
• To maintain the smooth operation of the Game Services (which includes activities such from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information (such as IP address as well as app- and OS-generated identifiers).
• The Game also allows players to communicate directly with each other via the text chat and voice chat functions. Player communication is a key part of players’ experience on the Service. Note that the audio chat function is OFF by default unless specifically enabled.
• If you choose to answer a survey, we collect survey response content that you choose to provide in the survey, such as email, country or region of residency, and gaming habits and preferences.
• If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns.

How will we use your information?

In relation to the Website: We use your information to enable you to optimise and improve the Website, provide you with news and updates to the Game, and consider your eligibility to participate in Game testing events and contact you regarding the same.

• In relation to the Game: We use your information to set up your account, enable you to use the Game, localise the Game experience, enable interaction between users of the Game, save your progress, ensure the safe and secure operation of the Game, address bugs, optimise and improve the Game, protect users, monitor our marketing initiatives, resolve user queries, and to comply with our legal obligations and enforce our legal rights.

Who do we share your information with?

We may from time to time use third parties and work with our affiliates to help us deliver the best possible experience.

• All third party service providers providing services for us (if any) are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game Services (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.

Where do we process your information?

We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

• We have servers for the Game Services in Singapore, the United States, Germany, Belgium, and the Netherlands. We also have support, engineering and other teams who may support the Game Services, including from Singapore, the United States, Germany, the PRC, Portugal, and Sweden.
• For EEA users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.

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 use a LI Account to register for the Game, 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.

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.

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.

Welcome to Insterra!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the game Insterra (“Game”), the main website for the Game (“Website”) (the Game and the Website, together comprise the “Game Services”) 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 Game Services. 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 Game Services. By using the Game Services 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 Game Services is Insterra (“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 https://dpo.proximabeta.com/public/dsar/link-page?id=b7462307-12fd-47b1-b2bf-512f87bd6f7b. You can also reach out to our data protection officer at https://dpo.proximabeta.com/public/dsar/link-page?id=b7462307-12fd-47b1-b2bf-512f87bd6f7b.

1. Cookies

We use cookies, webhooks and other similar technologies (“Cookies”) to enhance your experience using the Game Services. 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 Game Services for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction). Except with such consent, children must not use the Game Services for any purpose.

By children, we mean users under the age of 16 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.

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 the European Economic Area, Switzerland or the United Kingdom, it also identifies the legal basis under which we process your data.

4. How We Store and Share Your Personal Information

We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Game Services in Singapore, the United States, Germany, Belgium, and the Netherlands. The servers applicable to your use of the Game Services will depend upon your choice of server and/or location. We also have support, engineering and other teams who may support the Game Services, including from Singapore, the United States, Germany, the PRC, Portugal and Sweden.

For EEA 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 may occur are:

• Third parties that provide services in support of the Game Services, including providers of services that process information identified in this policy, for the purpose of providing the Game Services, providing cloud storage services (such as Google Cloud Platform and Amazon Web Services), providing anti-cheating functionalities, and authentication service (SCI Information Service Inc.). 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 Game Services (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 Game Services to you, e.g. Tencent Cloud.  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 Game Services 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.

7. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Game Services.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. You can access thepersonal information you have made available as part of your account by logging into your account.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.

Correction

You may have the right to correct personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account.

Erasure

You may be able to delete your account, or remove certain personal information that we hold about you. 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 Game Services 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.

Restriction of Processing to Storage Only

You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing 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 using the contact details set out below, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at https://dpo.proximabeta.com/public/dsar/link-page?id=b7462307-12fd-47b1-b2bf-512f87bd6f7b. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

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 Game Services 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:

Mailing Address: Vlkova 532/8, Žižkov (Praha 3), 130 00 Praha

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 use the Game Services, 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 Insterra process?

Insterra is a an open-world, tactical extraction shooter set in a world torn apart by extreme forces of nature.

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

• Level lnfinite Pass acount registration information including email address, user lD, nickname, user token, Open ID, date of birth,country); email address, if they wish to receive marketing messages about games; phone number, if this is added and linked to the account; customer support information, if they contact customer support; location (lP address); and account deletion information (email address, verification code, region, OpenID and user token) if they submit an account deletion request.

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

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 Insterra, 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 Adyen. 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 Insterra 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 con tacting us. You can also request a copy of your child’s personal information at any time.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Game Services, 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.

Some jurisdictions’ laws contain additional terms for users of the Game Services, 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 Game Services, 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 Game Services) located in Singapore, the United States, Germany, Belgium, and the Netherlands (as described in the Privacy Policy) where it is manually and electronically treated.

Argentina

Your rights

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 ).

Data transfers

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 your personal information and by using the Game Services, 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

Overseas Recipients

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.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us using the details provided.

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us using the details provided.

Children

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 Game Services.

Transacting Anonymously

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

Your Rights

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 ).

Data Transfers

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.

Bangladesh

Agreement

By accepting 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. 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, Singapore, the United States, Germany, Belgium, PRC, Portugal, Sweden and the Netherlands.

Age Restriction

In order to use the Game Services, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

Brazil

This section applies to users located in Brazil:

Consent Revocation

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 at here. This may affect our provision of the Game Services to you.

Parental and Guardian Consent

If you are under the age of 18, you should not use the Game Services for any purpose without first obtaining parental/guardian agreement to this privacy policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE 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.

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 from or about you or your device:

• Website Log-In Information, Subscription Information, IP Address, Technical Information, Playtest Registration Information, Puzzle Information, Data Statistics, Discord Information, Account Log-In information, IDIP Data, Survey (IMUR) Information, Databrain Information, XWID, SDK Data Monitoring Information, Email Segmentation Data, Customer Support Information, IP Address, Profanity Filtering Information, Chat Data, Log Data, Backend Data, Anti-Cheat Information, Sentry Information, Minor Compliance Information, Webview Information, Gamelet Information (as further set out in Section “How We Process Your Personal Information” above)

• 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 purposes as further set out in the Section “How We Process Your Personal Information” above.

We disclose each of the categories of personal information that we collect as described in Section “How We Process Your Personal Information” above.

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. In the past 12 months, we may have collected the following types of sensitive personal information about you:

• Your chat data

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. 

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;

• Right to Delete. Request we delete personal information we collected from you;

• Right to Correct. Request we correct inaccurate personal information that we maintain about you;

• 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 at here. 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 you to provide the Data Subject Request Information set out in the section “How We Process Your Personal Information”.  

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 using the details provided here.

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, please contact us using the details provided here. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

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

How We Use Your Personal Information

From the entry into force of this Privacy Policy, at the time of the collection of your personal data, we will request your prior authorization, by informing you about the specific purposes of the processing of your personal data for which such consent is obtained under the Privacy Policy.

Your authorization may be expressed (i) by writing, (ii) orally or (iii) through unequivocal conducts that allow us to reasonably conclude that your authorization was 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.

Your Rights

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 if you want to exercise any of these rights through our contact information in the section ‘Contact’ of this Privacy Policy.

Proceedings For The Exercise Of Your Rights

Queries (rights to access): You can file queries regarding the processing of your personal data by us.

Claims (right to correction and erasure): You have the right to file claims in relation to the processing of your personal data by clearly describing the facts that give rise to your claim.

Egypt

This privacy policy is provided in Arabic for users located in Egypt. In case of dispute, the Arabic version of this privacy policy shall prevail.  

By clicking the button to proceed or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this privacy policy. If you do not consent to this privacy policy, you must not use the Game Services.

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  Singapore, the United States, Germany, Belgium, PRC, Portugal, Sweden and the Netherlands.

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

Your Rights

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 using the details provided here.

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.

India

 Age Restrictions

Parental consent is required for children under the age of 18 years to use our services.

Sensitive Personal Information

Sensitive Personal Information under local law includes passwords, financial information (such as bank account, credit card, debit card or other payment instrument details), biometric data, physical or mental health, sex life or sexual orientation, and/or medical records or history, but does not include information available in the public domain, or provided under Indian laws, including the Right to Information Act, 2005.

Sharing Of Your Sensitive Personal Information 

Where we permit any third parties to collect and use Sensitive Personal Information, we shall use reasonable measures to ensure that the third parties do not further disclose the Sensitive Personal Information to the extent required by applicable laws.

Withdrawal Of Consent

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at here. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.

Indonesia

Consent

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.

Parental and Guardian Consent

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 the Game and use the Game Services.

Data Subject Rights

You have the right to access your personal information stored in our Game from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

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

Data Retention

We will retain your personal information in line with legal requirements.

Data Accuracy and Third Party Consent

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).

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 Game Services.

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, the United States, Germany, Belgium, PRC, Portugal, Sweden and the Netherlands.

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

How We Store and Share Your Personal Information

Your personal data may be transferred abroad and to third parties as follows:

Transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.

Your Rights

You have the right to be informed about our processing of your personal information, which we satisfy by providing this Privacy Policy to you. You also have the following rights as further described in Section 6 (Your Rights): the right to access, correction, erasure, restriction and to withdraw consent. Unless otherwise stipulated by law in Saudi Arabia, you will not be required to pay any fees in return for exercising these rights. We will respond to your request within 30 days of receiving it. Where you wish to make such requests, please contact us as set out in Section (Contact).

You also have a right to lodge a complaint with the Saudi Data and Artificial Intelligence Authority by contacting them directly. Their website is accessible at: www.sdaia.gov.sa

Data Destruction

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.

Kuwait

You represent that you are at least 21 years old, or 18 years old and have obtained parental/guardian consent and, therefore, legally capable of contracting under the applicable laws and regulations in 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 Game Services 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

Parental and Guardian Consent

If you are under the age of 18, please do not use the Game Services.

In the event you are agreeing to this privacy policy in order for a minor to access and use the Game Services, 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.

Your Rights

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 using the contact details provided above. However this may affect our provision of the Game Services to you.

Contact

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

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

• You can reach us using our online form here

Mexico

Age Restrictions

Please do not use the Game Services unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf).

Types of Personal Information We Use

For clarification purposes, in section “ How We Use Your Personal Information” you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations.

Purposes of Processing

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. You may object to the processing of your personal data for voluntary purposes as stated in the section “ Your Rights” below.

Please be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and carry out the transfer of personal data detailed in section “How We Store and Disclose Your Personal Information”.

Data Transfer Consent

In general, we do not require your consent to carry out the transfers detailed in section “How We Store and Disclose Your Personal Information”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.

By using the Game Services and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section “ Your Rights” below.

Your Rights

The sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only”, which include limitation to the use and disclosure of your personal data, and “Email Opt-Out” and “SMS Opt-Out” included in Section “ Your Rights” above also apply to users that are located in Mexico.  You also have the right to revoke the consent that you have provided us to process your personal data.

To exercise any of your rights, contact our Data Protection Officer using our online form here .

To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our Data Protection Officer using our online form here.

Cookies

Through the use of cookies, we collect certain information related to your browsing and device, some of which may be considered personal data (detailed in our Cookies policy). You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, you should consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionalities of the Game Services may no longer be available to you. For more information about our use of cookies and how to disable them, please visit our Cookies policy.

Morocco

The protection of your privacy is an important principle for us. We collect information for purposes strictly necessary for the proper use of the Game Services.

By accepting these conditions of use, you explicitly accept that your personal data may be subject to processing by the Game Services.

Kindly note:

• the identity of the Data Controller is Insterra, please contact us using the details provided here.
• 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” ( sub-paragraph “Objection”).

New Zealand

This section applies to users located in New Zealand:

Overseas Recipients

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.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at  here.

Correction

You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at here.

Children

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 Game Services.

Your Rights

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).

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Peru

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Data Protection Law (the “Law”).

You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as 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.

Contact

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

• Data Protection Team, responsible for the management and safety of your personal information

• Contact: You can reach us using our online form here .

Philippines

Minimum Age

You must be at least 18 years of age to be able to use the Game Services.

Your Rights

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.

Consent

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

• collecting and processing your personal information as described in the section “ How We Use Your Personal Information” above;
• 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 the section “How We Store and Disclose Your Personal Information” above.

Qatar

If you are using the Game Services 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

Collection and Use of Personal Information

We collect your personal information for the purposes described in this Privacy Policy.

With regards to the legal basis of processing personal information included in Section 3 “How We Process Your Personal Information,” the following legal provisions under the PIPA applies:

• (for consent): we use this information pursuant with your consent, pursuant to Article 15(1)(1) of the PIPA.

• (for complying with legal obligations): we use this information where necessary to comply with a legal obligation pursuant to Article 15(1)(2) of the PIPA.

• (for contractual necessity): we use this information where necessary to perform our contract with you to provide our Services, pursuant to Article 15(1)(4) of PIPA.

• (for legitimate interest): we use this information where it is in our legitimate interest pursuant to Article 17(1)(2),15(1)(6) of PIPA.

Third-Party Provision of Personal Information

We provide your personal information to third parties as described below in accordance with Article 17 (1) 1 of the PIPA

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:

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows in accordance with Article 28-8 (1) 3 of the PIPA:

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:

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.

Contact 

To protect your personal information and handle complaints relating to your personal information, we can be contacted at the following:

• Email: info@insterrasolutions.com

Website - Mandatory Consent language

To provide you with the Exoborne Website, we will need to collect, access, process and use the following personal information. You have the right to refuse, but if you refuse, you will not be able to register your interest on the Exoborne Website. Do you agree to our collection and use of the following personal information?

Items to be Collected

Website login information (via Level Infinite Pass): email address, password, user token and country

Subscription information: email address, IP address, country and language.

IP Address

Technical information such as IP address, device operating system (Android or iOS) and CPU information.

Playtest Registration Survey Information: information you provide when registering for our Game playtests, including age range, country/region, Discord ID or Steam ID, PC's Graphics Processing Unit (GPU), game duration, frequently played PC/ console games, email address, and other information you provide on our survey questionnaire (including your gaming habits, gaming preferences and device specifications).

Puzzle information: open ID, IP address, PC system version, email address and country

Data statistics: IP Screen Width, Screen Height, System OS, System OS Version, System language, User Agent

Discord information: Discord ID

Purpose of Collection and Use

Website login information (via Level Infinite Pass): to allow you to register, create and login to your account for the Website.

Subscription information: to send you notifications and updates about the development, progress and launch of the Game, as well as for recruitment for customer engagements and user testing of the Game.

IP Address: to perform statistics on page view and user view on the Website.

Technical information: for monitoring the performance of the Website and for troubleshooting, such as addressing and remediating technical issues and bugs.

Playtest Registration Survey Information: to determine if you are eligible to participate in existing and/or future Game testing events, and to contact you if you are selected to participate in a Game testing event and to further improve our Services and/or develop new services based on survey responses.

Puzzle information: to allow players to participate in puzzle solving activities / games on the Website and to contact winners for prize distribution.

Data statistics: to report key statistics from users’ engagement with the Website.

Discord information: to verify that you are eligible to join our exclusive Discord content creator channel.

Period of Retention and Use

Website login information (via Level Infinite Pass): Stored for the lifetime of user's use of the Level Infinite Account (i.e. until account deletion in accordance with user's request, upon which it will be deleted within 30 days). Where you do not request for account deletion, such data will be retained for 30 days after the Website is shut down, before it is deleted.

Subscription information: Stored for as long as you subscribe to receive our notifications and updates and deleted within 7 days from receipt of your unsubscription request.

IP Address: Stored for the lifetime of the Website or deleted within 30 days from a data deletion request (or a shorter time period as required by the relevant jurisdiction’s data protection law).

Technical information: Stored in accordance with the retention periods stated in the Tencent Cloud Privacy Policy and Data Processing and Security Addendum for Real User Monitoring.

Playtest Registration Survey Information: Stored for 30 days after completion of the Game playtests (closed beta test), or deleted within 30 days of your deletion request, whichever is earlier.

Puzzle information: Stored for the lifetime of the Website or deleted within 30 days from a data deletion request (or a shorter time period as required by the relevant jurisdiction’s data protection law).

Data statistics: Stored for 3 months by Google Analytics. We do not store this information.

Discord information: Stored for the lifetime of the Website or deleted within 30 days from a data deletion request (or a shorter time period as required by the relevant jurisdiction’s data protection law).

Website - [Mandatory] Overseas transfers of my personal information

Website - [Mandatory] Third party provision of personal information

Mandatory Consent language 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

• 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, Singapore, the United States, Germany, Belgium, PRC, Portugal, Sweden and the Netherlands.

Access

You have the right to access your personal information, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at here.

Correction

You have the right to correct any of your personal information that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact here.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at here.

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 Game Services.

Where you request to withdraw consent, refrain from further processing of data, erase, rectify or complete your personal information, we will provide you with our response to the request within 21 working days.

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 Game Services .

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 Game Services.

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 at here.

Please include the word “Thailand” in the subject line of your request.

Türkiye

Our Data Controller Representative in Türkiye for the purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations, Özdağıstanli Ekici Avukatlık Ortaklığı, can be contacted at localdatarep_sharkmob@iptech-legal.com. Please include the word “Türkiye” in the subject line of your email.

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:

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 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.

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 (Contact).