Effective Date : 28 June 2023
Last Update : 28 June 2023
MAXION PTE., Ltd (“we”, “our”, “us”, “the Company”) is committed to protecting the privacy and security of the information we collect and being transparent about the ways in which we collect and process your information. This statement (the “Privacy Policy”) sets forth our policies and practices for handling the information we collect from or about you. It applies to the game websites and online services that we operate and that link to this Privacy Policy, such as the game website (the “Website”), our Software (the “Services”), our online communities, and our customer services(collectively, the “Services”)
Please note that the scope of this Policy is limited to information collected or received by MAXION PTE., Ltd through the use of our Service. MAXION PTE., Ltd is not responsible for the actions of third party persons or companies, the content of their sites, the use of information you provide to them, or any products or servicesh they may offer. Any links to these sites do not constitute our sponsors, or affiliations with, these persons or companies. By using the Service, you have agreed to this Policy and the processing of your data, including your personal information, in the manner provided in this Policy. If you do not agree to these terms, do not use the Service.
1. Collection of Personal Data
In this notice, “personal data” means any information about an identified or identifiable individual. We process the following categories of personal data from you when you use our Services:
- Contact information, such as your phone number and email address.
- Registration information such as personal information, your game account’s information and your in-game or character nickname.
- Automatically collected information such as cookies, and in-game log (such as quest log and war log), transactions log. In addition, we collect the following categories of personal data, if you wish to use certain services we provide:
- Information required to facilitate the processing of your purchases through third-parties like the player key, receipt information.
- Information required to link your game account with your crypto wallet account, such as Wallet address.
- Information necessary to manage inquiries and requests from you such as information related to the issue you are contacting us about.
- Information necessary to organize an event such as your in-game nickname or name of the relevant server.
We receive the above categories of information from you when you directly provide it to us, or from other sources, including from users of our Services and third-party services and organizations. (e.g. Google, Apple, Facebook). Please see Appendix II for more information on personal data collected from third parties.
We do not collect any sensitive information (i.e. data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation) or any data relating to criminal conviction and offences from you.
2. Use of Personal Data
We will use your personal data for the following purposes:
- To provide you with the Services. We may use your information to open and maintain user accounts, facilitate the functionality of our Services, customize the Services, to provide forum and community features, to respond to your inquiries and to organize and manage events.
- To improve the quality of our Services. We may use your information to maintain, improve, and administer our Services, including by troubleshooting, data analytics, and testing.
- To keep our Services and users safe. This includes to detect users illegally using our programs; and to otherwise prevent and respond to fraud, abuse, security risks, and technical issues.
- To send you electronic correspondence. We may send you emails or otherwise communicate with you in order to manage inquiries and requests from you or otherwise to communicate about your use of the Services. Upon your request, we may also send you a newsletter in an electronic form.
- To comply with applicable laws and regulations. This includes using your information to ensure compliance with legal obligations (such as recordkeeping obligations), solve disputes, enforce our contractual agreements, and to establish, exercise or defend legal claims.
We will use your personal data on the following legal bases as described in Appendix I:
1. To perform a contract we have entered into with you.
2. To comply with a legal obligation or
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal data on the following less common legal bases:
To protect your interests (or someone else’s interests).
Where your consent is given or
Where it is required to defend or pursue legal claims.
Please see Appendix I for more information on those legal bases.
3. Disclosure of Your Information
Maxion does not share your personal information except as agreed by you or as explained below: With your consent, for example, when you agree to us sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies. If you no longer want to allow us to share your information with third parties, please contact us at https://maxion.atlassian.net/servicedesk/customer/portals/.
We may release your information as permitted by law, such as to comply with a subpoena, or when we believe that the release is appropriate to comply with the law; fraud investigation, respond to government requests, enforce or apply our rights; or to protect of our company, our users and others rights, property or safety. This includes exchanging information with other companies and organizations for fraud protection.
MAXION PTE., Ltd may share your information regarding mergers, sales of our assets, or financing or acquisition of all or part of our business with other companies. You will be notified by email and / or notice on our site about any changes in the ownership or user of your personal information. We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors and other third parties.
4. Policy Changes
We may update this privacy policy to reflect changes to our information practices. We encourage you to periodically review this page for the latest information about our privacy practices.
5. Security
MAXION PTE., Ltd takes reasonable action to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store information collected on the Service in a secure operating environment that is not publicly available, we cannot guarantee the absolute security of that information during transmission or storage on our system. Furthermore, while we strive to ensure the integrity and security of our networks and systems, we cannot guarantee that our security measures will prevent third-party hackers from illegally gaining access to this information. We do not guarantee or represent that your information will be protected against loss, misuse, or alteration by third parties. However, there are no methods of transmitting over the Internet, or methods of electronic storage, that are 100% safe. Therefore, we cannot guarantee absolute safety.
6. Access to Personal Information
If your personal information changes, or if you no longer want our services, you can correct, update, or delete inaccuracies by making changes in your account settings or by contacting us at https://maxion.atlassian.net/servicedesk/customer/portals/. We will respond to your access request within 30 days.
7. Data Retention
We retain, if any, your Personal Data only for the period of time as necessary to achieve the particular purpose for which the information was processed.Typically, without your request to erase Personal Data and also without legitimate reason to keep it longer, after the termination of our relationship, we retain your information for 1 month after deregistration of your Game Account or for the duration described in the table below:
| Personal Data Retained | Retention Period |
|---|
Data necessary for performance of the agreement or cancellation of subscription Records of payment Tax and accounting records Records of electronic financial transaction | 5 years |
Records of a customer complaint or dispute resolution Records that Game account or character was banned based on the violation. | 3 years |
Records of correspondence with User for statistics purposes; to deliver, develop and improve our Service and the Game; to support Users in using the Services and the Game; to ensure security and confidentiality of the User’s account and data; to restore access to the User’s account, Services and/or to the Game; to restore lost payments made by the User. Record of User’s Game' preferences, progress in Game, playtime, as well as information about device settings, unique device identifiers and crash data. | 3 years |
Record of in-game character activities, logs, and data on in-game transactions, log-files and in-game chats. Records of misuse by users of Game or Services | 3 years |
Computer communication or internet log-in records of computer communication or facts about an internet user’s utilization of telecommunication service | 3 years |
Record of IP address and other online identifiers | 3 years |
Log-files and chat in case of dispute with the User | The duration of the dispute |
For the clarity, we retain your information insofar as such information will be processed solely for archiving purposes in the compliance with our legal obligation or statistical purposes, subject to appropriate safeguards, in accordance with the data protection laws, for your rights and freedoms. The appropriate safeguards shall ensure that technical and organizational measures are in place to ensure respect for the principle of data minimization.
8. Our Policy About Children
We do not intentionally collect or request personal information from anyone under the age of 13 or intentionally allow that person to use our Services. If you are under 13, do not send information about yourself to us, including your name, address, telephone number or email address. No one under the age of 13 can provide any personal information. If we find out that we have collected personal information from a child under 13, we will delete that information as soon as possible. If you believe that we may have information from or about a child under the age of 13, please contact us at https://maxion.atlassian.net/servicedesk/customer/portals/
9. Marketing Preference
You can choose not to receive promotional emails from us by clicking the “Unsubscribe” button at the bottom of the email. If you choose not to receive, we can still send you non-promotional emails, such as emails about your account or our ongoing business relationship.
10. Your Duty and Rights in Relation to Your Personal Data
Your duty to inform us of changes. It is important that the personal data we hold about you is accurate and current. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected. Your rights in connection with personal data
You may be entitled, in accordance with applicable law, to the following rights to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction and/or deletion of your personal data.
- Request the restriction of the processing of your personal data.
- Request receipt or transmission to another organization, in a machine-readable form, of the personal data that you have provided to us.
- Object, at any time, to the processing of your personal data by us or
- Withdraw your consent.
To exercise any of your rights, please contact us by using the contact details at the end of this policy. We may need to request specific personal data from you to help us verify your identity and confirm your right to access the personal data (or to exercise any of your other rights). This is another appropriate security measure to ensure, for example, that personal data is not disclosed to any person who has no right to receive it.
In the event that you wish to make a complaint about how we process your personal data, please contact us and we will endeavor to handle your request as soon as possible.
11. Notification of Changes
We reserve the right to update and change the terms of this Privacy Policy at any time. If we decide to update and materially change the terms of our Privacy Policy, we will post those changes in our Services and/or on the applicable Sites, and in the updated Privacy Policy. You should periodically check this Privacy Policy for updates.
By continuing to access or use the Services after we have posted an updated Privacy Policy or have provided you with notice of a modification, you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.
12. Links to Third Party Websites, Services and Offers.
Our Service may contain links to other websites, services and/or offers from third parties. We are not responsible for, nor will it be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information you voluntarily chose to provide to them. You should review the applicable privacy policies and information practices of such third parties carefully before providing personal information to them. Moreover, if you have any questions or concerns, you should contact the third party directly.
13. Users Outside Singapore
The Company is a Singapore company and Company’s business operations are primarily conducted in Singapore. We operate our company and administer this Privacy Policy under applicable laws and regulations of Singapore. If you use our Service from outside Singapore, you are thereby consenting for your personal information to be transferred to, stored in and be processed in Singapore, South Korea and/or in other countries by the Company and/or its Affiliates in the manner described in this Privacy Policy. Your consent to this Privacy Policy followed by your submission of your personal information represents your agreement to such transfer, storage and processing of information.
As described elsewhere in this Privacy Policy, when you submit personal information via our Service, the information is housed in secure databases, equipment and servers located in Singapore, South Korea and/or in other countries. The databases, equipment, servers and software we utilize may be owned by third party providers.
Users in certain jurisdictions may have a right to access his/her personal information held by the Company and/or its Affiliates. Your right of access to such personal information can be exercised in accordance with applicable laws, rules and regulations.
Company officially notifies that Company does not provide any Services to a European or American User. If you are a European or American User, please do not attempt to access Services or to play any game on or through any service of Company. Further, if you newly acquire the nationality, or at any reason at all, by which you become a European or American User after your using Services, you should notify such fact to Company for our terminating your access to the Services under the condition of the relevant TERMS OF SERVICE or this Privacy Policy.
please contact us at https://maxion.atlassian.net/servicedesk/customer/portals/
14. Language
The controlling language of this Privacy Policy is English. If you have received a translation into any other language, it has been provided for your convenience only. The English version of this Privacy Policy shall govern to the extent of any inconsistency between the English version and any translated version.
15. Contact Us
If you have any questions, inquiries, requests, complaints, or comments regarding this Privacy Policy, or have other questions or suggestions about our information practices, please contact us at https://maxion.atlassian.net/servicedesk/customer/portals/
16. APPENDIX I
Purposes for Processing USER Data
| Purpose of Use | Categories of Personal Data | Legal Basis for Processing |
|---|
| Providing products and services | - Customer data, Identifiers, Network information, Device information, Usage data
| |
| Identifying individual users for provision of services | - Customer data, Identifiers, Device information
| |
| Improve the quality of our service, user experiences and fix bugs | - Network information, Device information, Game data
| - Our legitimate interests to improve our services
|
| Detecting and preventing illegal, unjust or unapproved use of service | - Payment information, Identifiers, Network information, Device information
| - Our legitimate interests to protect our business rights and services
|
| Managing inquiries and requests from you | - Customer data, Device information, Game data, Payment information, Activity data, Customer service data
| - Contract, if your request relates to your use of our services
- Your consent, if you are contacting us in another context
|
| Organizing and managing events | - Activity data, Usage data, Network information, Device information
| |
| Sending out prize (e.g. game item) to the winner of the event | - Customer data, Identifiers, Status of your consent
| |
| Management of cookie information | | - Consent when the information is collected through non-essential cookies
- Augh essential cookies
|
| Planning, performing and managing the (contractual) relationship with you including processing the payment | | |
| Ensuring compliance with legal obligations such as record keeping obligations | - Customer data, Identifiers, Network information, Device information, Status of your consent, Game data, Payment information, Customer service data
| |
| Solving disputes, enforce our contractual agreements and to establish, exercise or defend legal claims | - Customer data, Identifiers, Network information, Device information, Status of your consent, Game data, Payment information, Customer service data
| - Our legitimate interests to establish, exercise and defend our legal rights
|
17. APPENDIX I
INFORMATION COLLECTED FROM THIRD PARTIES
| Third Parties | Purpose of Use | Information collected |
|---|
| SARD Anti-cheat | to maintain fairness and integrity in online games and services by detecting and preventing cheating. | - Identifier, Network information, Game data, User Behavior
|
| Google analytics | to track and analyze website traffic and user behavior in order to improve website performance and optimize marketing strategies. | - Website Traffic, Traffic Source, User Behavior
|
