Privacy Policy

The Data Controller under this Privacy Policy is BILIBILI HK LIMITED (“bilibili”, “We”, “Our”, or “Us”).

We greatly recognize and values the privacy of people (“You” or “User”),who visit Our websites, use or access Our games, whether played on mobile devices, PCs, Our websites or other approved platforms (“bilibili Game(s)”), and/or otherwise use or access any of Our provided services (“bilibili Services” or “Our services”).

The Privacy Policy describes why, how and scope We collect, store, process, transfer and use your personal data, and the choices and rights You have about the personal data You provide or We collect in connection with our services. By accessing Our websites or otherwise using our services, You acknowledge that You have read, understood and accepted the following terms. If you do not agree to the processing of your personal data in the way described in this Privacy Policy, please stop using our services.

bilibili may periodically amend the Privacy Policy. We will announce to You by revising the date at the top of this Privacy Policy and notify You in an appropriate and practicable way to obtain your consent (and/or the consent of your parent/guardian, if applicable) again if We make any material changes to the Privacy Policy. .We encourage you to periodically review the most current version of this Privacy Policy.

What Data do We collect?	The Data that We may collect about You broadly falls into three categories, Data You directly provide to Us, Data that We collect through technologies, from You when You use Our services, and Data that We collect from third party sources.
How will We use the Data?	We use your Data to provide the Services and to improve them. We use your Data to personalize the content You receive and ensure your safety. Where appropriate, We will also use your Data to serve You targeted advertising.
How We provide your Data to a third-party?	In specific scenarios,We share your Data with advertisers and third-party service providers, such as cloud storage providers, data analytics service providers, logistics service providers. We also share your Data with our business partners, other companies in the same group as bilibili. Where and when required by law, We will share your information with law enforcement agencies or regulators.
How long do We retain your Data?	Generally, We only need to store your Data in the shortest period of time possible for provision of our Services and after such period, We will delete or anonymize your Data as per the requirements of relevant laws and regulations. We will also retain your data if there are legitimate reasons for the existence of legal permissibility, such as a longer period of data storage provided for by law, or We believe it is or will be necessary for the establishment, exercise or defense of legal claims.
Where do We process your Data?	Pursuant to our contract with You, your Data may be transferred to, and processed in, countries or regions other than the country(region) in which You are resident, and can be accessed by Our support, engineering and/or our affiliates around the world.
How can a user exercise his/her rights over his/her Data?	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 any changes to this Privacy Policy?	We will update this Privacy Policy from time to time and will notify You of such in one or several manners such as push notification, website announcement or pop-ups. You should look at this Privacy Policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this Privacy Policy, which reflects the effective date.

The Data that We may collect and process data about You broadly falls into the following categories:

We collect data of account, including email address (if You choose to use Our services by email), cellphone number( if you choose to use Our services by phone), password, username, nickname and profile picture, on the legal basis of performing Our contract with You to provide Our services, and use such this information to create the account for your usage of Our services as You request.

We use AIHelp customer supporting system to provide the customer service. According to what you are inquiring about, we will collect your purchase information (including purchase time, product, currency, cost), device information, user ID, your chat data and game data regarding to customer service with it. We use such information to help identify your account to enable Us to troubleshoot problems with your account or games, communicate with You and respond to your specific requests or questions. It is necessary for Our performance of a contract with You.

Ÿ · Data provided to us when You participate in online discussions or otherwise interact with Us;

Ÿ · Data provided to us when You voluntarily complete a customer survey or provide feedback / requests on any of Our message boards or via email;

Ÿ · If You get the digital prize(s) for participating in Our game-based events, We may collect your name, contact information, email address, in-game account ID and zone ID, to send the prize(s) to you.We may collect your identity card or passport information as required by applicable laws. We will collect such data with your consent.

We may also proactively collect Data through technologies, from You when You use Our services. In addition to providing you with the services and features related to the Game, we may also use these information for purposes such as modifying or improving features, managing advertising, addressing technical issues, preventing fraud, and conducting data analytics and it is necessary for provision of services and the security of the Services.

We will collect it to determine the country or region You are in and lock the Services region to that, to allow You to connect to the services and We may use your IP address to help to solve disputes concerning your account. The legal basis is legitimate interests pursued by Us.

Our services enable in-app purchases and We collect your IP address, device language, order number, user ID, payment method, amount, currency, product ID, quantity, order creation time, purchase time, transaction completion time, user ID, user name, and character name to assist you in completing the transaction. Please aware that such payment transactions are mostly completed through the app store via your App Store account or Google Play account, or through the payment method You choose.

Ÿ Gameplay data: including game setting, level, heroes, scores, open ID、Game ID、operating system, region ID\game server ID, , player nickname, character ID, character level, player balance, account status, account binding status, registration time, latest login time, player type.

Ÿ Game behavior data: including your match information in Games, your online time, click record (battle record, mall record, activity record, social category), your in-game interactions (such as friends list).

Ÿ Game log information and game statistics: including character ID, game account, user nickname, country code, device system version, device brand, IDFV, device model, device manufacturer, device name, screen resolution, screen orientation, CPU model, GPU information, RAM, client exported IP, phone memory, login channel ID, operator name, network type, signal strength.

We collect such information for the purpose of analyzing the usage of Game feature, optimize and improve experience, recording your game behavior and providing the Services and provide troubleshooting such as addressing and remediating technical issues and bugs. We process such data on the legal basis of performing our contract with you to provide our services.

When You use Our services on a mobile platform, We may collect your device data (including application version, unique device identifier, advertisement identifier, system language, device name and model, the version of your operating system, system and its version number, MAC address) every time You log in to the Services or make an in-game purchase or use customer service for the purpose of ensuring game security and verification, identify and address bugs and assess function for optimization, and monitor the success of our advertising and marketing programs (if any). It is necessary for Us to perform our contract with you to provide our services.

We will collect Security-Related Information (including your SDK log data, server IP, Open ID, system information (system version, brand, CPU architecture, country language), root status, application version, device information (including device type, IDFA, network type, brand, language region), jailbreak status (iOS) for security purposes in order to detect offensive and sensitive wording to provide a fair and secure online environment. it is Our legitimate interest to ensure the security of Our services. You know and understand that since there are multiple versions of the Game, the above information is collected for the purpose of adapting, developing and updating for devices of different versions.

We will collect advertising ID and some device information (such as device ID, device name, device type, system and version, MAC address, IDFA), registration time and login time. We use such information to evaluate the effectiveness of our advertisements and ensure security of Our services.

Most of Our services support You to log in with your social media account (e.g. Google, Apple). We may collect personal information You authorized the third-party social media to share with Us.

In accordance with your relevant privacy settings and authorizations on third-party social media,we will collect your information as follow:

Ÿ Google: We will collect your authorization ID, nickname, profile picture (if any), email address, location, and whether the email address is authenticated from Google, only the authorization ID, nickname, profile picture (if any) will be saved.

Ÿ Apple：We will collect your authorization ID, email address, whether the email address is authenticated, whether it is a private email, current timestamp, and expiration timestamp，only the authorization ID will be saved.

We use such data to enable You to link, connect, or login to your account with a third-party social media. We process such data on the legal basis of performing our contract with you. Exactly what information We receive from your social media will depend on your social media privacy settings. You should always review, and if necessary, adjust your privacy settings on the Third-Party Social Networks before linking or connecting them to our Service.

From time to time, We may receive personal information about You from third party sources. For example, if You click on an advertisement to direct You to one of Our services or Games, We may receive the information that allows Us to know which ad network and advertising campaign your installation was originated from.

i. We collect and process your personal information on lawful grounds permitted by law, which may include, in accordance with applicable data protection legislation:

Ÿ You have consented to our collection and processing of your personal information;

Ÿ To enter into and/or perform our obligations under our user agreement with you and to provide our services;

Ÿ Other legal reasons, including any legal or governmental and regulatory request, or for purposes of public interest.

Ÿ allow You to access and use, or restrict your access to and use our services;

Ÿ analyze and manage Our services for system administration, user service, security, fraud-detection, checking the authenticity of an account owner, archival and/or backup purposes

Ÿ correct bugs or errors, improve Our services and respond to customer desires and preferences, including language and location customization, personalized support and instructions, and other responses;

Ÿ deliver advertising, testimonials, and marketing messages that may be interested in (you can choose to turn this feature on or off in the device settings as stated hereunder);

Ÿ perform user agreement with you and to take action against violations in accordance with the user agreement;

Ÿ provide you with personalized display, personalized push and other personalized experience;

Ÿ send you notices, keep You up to date with the latest product announcements, provide software verification, upgrades and administration, notify of special events, offer you to participate in our surveys or activities, and provide other information pertaining to Our services;

Ÿ protect the integrity, safety, and security of Our services or users, comply with legal obligations, and enforce compliance with the Game User Agreement and/or other restrictions placed on your use of our services;

Ÿ investigate claims and/or legal actions, violations of our policies and procedures, and compliance with relevant applicable laws and legal process;

Ÿ comply with applicable laws, regulations, or legal process as well as industry standards and Our company policies; or

Ÿ prevent, investigate, identify, or take any other action with regard to suspected or actual fraudulent or illegal activity, or any activity that violates our policies.

(1) For the purpose of providing personalized advertisements(if any）, You acknowledge and agree that based on your consent We may collect and process the data to:

We may also use the data You provide to send You, or have Our authorized contractors to deliver advertisements, market research or surveys.

(2) Pertaining to the marketing or promotional communications, You may opt-out of

receiving such communications in accordance with the instructions therein, such as email, contacting customer service, or other contact methods provided by Us.

(3) Without Your consent, We ensure that We will not use your data for marketing purposes, You may also withdraw such consent at any time while without impact on the validity and lawfulness of data usage prior to such withdrawal. For the avoidance of doubt, if We know that You are a registered user under the age of majority in your jurisdiction, We will not target you with advertising.

(1) We do not share personal data that directly identifies You (such as your name, e-mail) with independent third parties unless:

ii. if We are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials;

iii. when We believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; or

iv. if necessary, to protect the vital interests of us and any of its users (such as to prevent death, bodily harm, or serious damage to property), public security and public interests; or

v. if We sell part or all of Our assets to the third parties, We may share your data with the buyer. In the event of this circumstance, the buyer will comply with this Privacy Policy, the related laws and regulations.

(2) We may share anonymous or aggregated data, or other data that does not directly identify You with other parties. You acknowledge that You have foreseen and agreed to the occurrence of such disclosure when You provide your personal data.

i. Other In-Game Users. We support and often encourage You to interact with other players. In most games, other players will see your name, player profile, in-game activities and read messages You have posted depending on the setting adopted by You. Any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal and sensitive data at any time on or through Our services.

ii. Competent Authorities. We may provide a certain portion of your personal data to judicial or administrative authorities as so requested. Besides, We may disclose certain portion of your personal data within a strictly limited scope of recipients when We reasonably think it is necessary to protect Us, Our users or a portion of the public.

iii. Related Group Companies of Us. We may share your information with our related entities, including Our parent and sister companies. For example, We may share your information with our affiliates for customer support, marketing, or technical operations. Where We share your personal information with Our affiliates, they handle your personal information in accordance with this Privacy Policy.

iv. 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-organize 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.

(3) For the purposes set out in section 2 of this Privacy Policy, we may need to provide your personal information to third party service providers in order for them to assist us in providing relevant services to you. The third party service providers we may use include:

i. i.Providers of Analytics Services. They process information identified in this Privacy Policy on their servers for the purposes of assisting Us with acquiring users for the Game and analytics purposes to improve your gameplay. All companies providing services for Us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

Name of recipient	Types of Personal Information provided	Purpose of Use by Recipient	Period of Retention and Use by Recipient	Opt out
Appsflyer https://www.appsflyer.com/services-privacy-policy/.	device information about such as device type, IP address, device ID and information about your engagement with the webpage, applications and ads.	User acquisition purposes and to monitor the effectiveness of our advertisements	In accordance with the Appsflyer privacy policy	visit https://www.appsflyer.com/optout or email at privacy@appsflyer.com
Firebasehttps://firebase.google.com/support/privacy/	Technical information, technical identifiers, engagement information, contact information, event data	Data analytics	In accordance with the Google Developer License Agreement and privacy policy	visit https://adssettings.google.com

ii. ii.Advertising Service Providers. We may share your information with our ad delivery platforms or platforms used to analyze the effectiveness of ad delivery. These platforms help promote our services by placing advertisements on other platforms, or show you advertising content that we think may be of interest to you, and help evaluate the effectiveness of our and our partners' advertising.

Ÿ Social networking portals who provide login and/or content-sharing service to and in Our services;

Ÿ Payment service providers who provide payment services, such as assisting Our services to run on, facilitating users’ payment, and maintaining a record of the users’ transaction history;

Ÿ AIhelp service provider. We will share your device information, your chat data or game data regarding to customer service with it.

We and/or authorize third party（e.g.Google）may use cookies (small text files used to add functionality or track site usage) and related technologies to collect the following data from you:

Ÿ record your IP address to determine the path users take to our site and to identify repeat visitors to our site

Ÿ collects information about the websites or sources that link or refer you to our Services, and/or

Ÿ collect technical data about the machine and device you use to access our Service.

We and/or authorize third party may use cookies or other similar technologies when you use the Service for the following specific purposes.

Ÿ To help us recognize you as a registered user and to retain preferences or data that you have previously provided;

Ÿ To help us understand what visitors (including users) do on our Services or which pages or sections are most popular;

Ÿ To help us provide you with advertisements that we believe are relevant or of interest to you based on the data you provide;

Ÿ To provide, develop, maintain, personalize, protect, analyze and improve our Services; and/or

Ÿ To prevent, identify and protect against fraud and other illegal activities.

We do not use cookies or other similar technologies for any purpose other than those described in this Privacy Policy.

Among other things, we use cookies from Google including Google Analytics. You can learn more about how those cookies work by visiting https://business.safety.google/privacy/.We do not control cookies in third party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology.

If You wish to block, erase, or be warned of cookies, please refer to your browser or mobile device’s instructions or help screen to learn about these functions. You may not be able to delete or disable cookies on certain mobile devices and/or certain browsers.

Remember, if a browser or mobile device is set not to accept cookies or if a user rejects a cookie, some portions of the Website or Service may not function properly. For example, You may not be able to sign in and may not be able to access certain Website or Service features or services.

To provide our services and/or to meet legal requirements, we may transfer your data to other countries and other regions outside of where you are located( such as Singapore, Japan, South Korea, Germany and the United States).Our corporate group operates around the world and your personal information may be transferred to, and processed in, countries other than the country in which You are resident, and can be accessed by Our support, engineering and/or our affiliates around the world. These countries may have data protection laws that are different from the laws of your country. When you submit personal data to us you may transfer your data across borders. We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. Internally, we also require these affiliates of group and Our services providers or business partners to protect your personal information when processing your personal information to provide Services to You. In particular , our international transfer of personal information collected in the European Economic Area, the United Kingdom, and Switzerland is governed by Adequacy Decision. The European Commission adopts adequacy decision on Japan.

We will only store your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be required or permitted under applicable law(whichever is longer). Upon the expiration of such period, your personal data will be deleted or anonymized, as provided by applicable law.

In the case You request to remove or delete your personal data, We will assess whether such data is necessary for Our legitimate business interests, such as to comply with Our legal obligations, resolve disputes, and/or enforce the agreements between You and Us. If so, We will retain your data until it is not necessary. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable services.

In accordance with applicable data protection legislation, you may have different data subject rights in relation to the personal information you provide to us and that we collect when you use the Game.You may exercise any of the rights described in this section by using any functionality available while using Our services and/or sending an email to [JJKPPservice@biligames.com]. We will respond within 30 days though this may be extended by a further two months in certain circumstances. Please note that We may ask You to verify your identity before taking further action on your request.

You have the right to access your personal data that We hold about You. In some jurisdictions, applicable law may entitle you to request copies of your Data held by us. You may also be entitled to request copies of Data that You have provided to Us in a structured, commonly used, and machine-readable format, should You have such requirement, please contact Us. According to Our reasonable and unilateral judgement, if your verifiable request affects or will affect the rights or freedom of other users or is manifestly unfounded or unreasonable, We reserve the right to charge a reasonable fee (taking into account the administrative costs arising therefrom) or refuse to act on the request.

If We process your personal data, We shall endeavor to ensure by implementing suitable measures that your personal data is accurate and up-to-date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, You have the right to obtain rectification of your inaccurate personal data without undue delay.

You have the right to obtain deletion of your personal data, if the reason as stated in Article 2 of this Privacy Policy does not exist anymore, or if there is another legal ground for its deletion, subject to submitting a verifiable request in the form of sending an email.

We provide You with the service of account cancellation. You can delete your account by clicking 【Settings】-【Delete your account】in most of our Games or You can contact Us to exercise your right. Please read the instructions of the cancellation page carefully. Should You choose to cancel the Game account, We will delete or anonymize all relevant personal data generated by You in the Game in a timely manner in accordance with relevant laws and regulations, unless otherwise required by laws and regulations.

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 defense of legal claims or freedom of expression) but We will let You know if that is the case.

To the extent provided by applicable laws and regulations, You may withdraw any consent You previously provided to Us for certain processing activities. 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. Should You withdraw your consent or authorization, We may no longer continue to provide You with the services related to the withdrawal of the consent or authorization, and will no longer process your related personal data. However, your decision to withdraw your consent or authorization will not affect the processing of personal data previously carried out based on your authorization.

In accordance with applicable laws and regulations, you have the right to object to our specific processing of your personal information, such as when we process your personal information for direct marketing purposes, or where we process your personal information on the basis of legitimate interests or public interest. If you object to our processing of your personal information based on legitimate interests or in the public interest, we will no longer process your personal information for that purpose, unless there are specific reasons provided for by law, such as compelling and prevailing legitimate grounds for the processing or where the data is necessary for the establishment, exercise or defence of legal claims.You also have the right to lodge a complaint at a supervisory authority. Where your personal information is processed for direct marketing purposes, You may, at any time ask us to cease processing your data for these direct marketing purposes.

As required by applicable law, you have the right to restrict the processing of your personal data. in particular where:

Ÿ We no longer need your Data for the purposes of the processing, but You require the Data for the establishment, exercise or defense of legal claims; or

Ÿ You have a request to refuse a particular processing and are still awaiting the outcome of our processing.

If You think we have infringed data protection laws, you can lodge a complaint with or report to a supervisory authority within your jurisdiction, or file a lawsuit to a judicial authority within your jurisdiction.

Security of Our users' Data is a priority at Us, and We are continuously implementing and updating administrative, technical, and physical security measures such as access control, compressed encryption to help protect your Data against unauthorized access, loss, destruction, or alteration.

Unfortunately, the transmission of information via the internet is not completely secure. While We strive to protect your personal data, We also remind You to be aware of hacking, cyber-attacks, and other risks on the Internet.

We strongly urge You to take every possible precaution to protect your personal data when using our services, including but not limited to changing your passwords from time to time, not reflecting your real name or other personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures.

If We learn of a security incident, We may attempt to notify you electronically or post a notice on the website so that You can take appropriate protective steps. If there is a security breach occurs, In accordance with the provisions of applicable law,we may also post a notice on the Website. We will send an emergency report to authorities in case that the security incident is serious and assist authorities to take steps to prevent further harm.

Children (usually considered to be under the age of 18, depending on where You reside) must not use the bilibili Game(s) for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction). For users located in certain regions We have listed the relevant minimum age as of the date of this Privacy 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.

We do not intent to and will not knowingly collect personal data from children without consent from their parents or guardians. We strongly urge parents and guardians to instruct their children never to disclose or give out their personal data when using Our services without the prior permission of their parent/guardian. If We learn that We have collected personal data about a child, We will delete that data as quickly as possible. Also, if You believe that We might have any data from or about a child, please contact Us.

If You are a parent or guardian of a child and are required to provide your email address as part of the verification process, We will process such email address for the purposes of notifying You of changes to processing or this Privacy Policy, and for verifying data subject requests from You, in each case in accordance with Our legal obligations.

Recipient and contact information	Country to which Your Personal Data is to be Transferred	Types of Personal Data	Purposes of Use by Recipients
Appsflyer (privacy@appsflyer.com)	United States unless otherwise described in the service provider’s privacy policy	device information about such as device type, IP address, device ID and information about your engagement with the webpage, applications and ads.	User acquisition purposes and to monitor the effectiveness of our advertisements
Firebasehttps://firebase.google.com/support	United States unless otherwise described in the service provider’s privacy policy	Technical information, technical identifiers, engagement information, contact information, event data	Data analytics
AIHelpcontact@aihelp.net	United States	depending on what you are inquiring about, such as purchase information, device information, user ID, your chat data and game data regarding to customer service with it.	Customer service
Cloud service providers	Japan、Singapore	Game account data, transaction-related data	Data storage, data analytics

Act on the Consumer Protection in Electronic Commerce, Etc.	In an electronic commerce or a mail-order sale: Records regarding labelling and advertising (6 months) Records regarding execution or withdrawal of a contract (5 years) Records regarding the payment of a price and the supply of goods and services (5 years) Records regarding customer services or dispute resolution (3 years)
Protection of Communications Secrets Act	Log records, IP address (3 months) The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

Notwithstanding the foregoing, some countries, states, provinces, or other jurisdictions do not allow the exclusion of certain warranties or limitations of liability described above, so some of the above may not apply to you. In addition, you may have other legal rights in your jurisdiction, and nothing in this Policy is without prejudice to the legal rights you may have in the applicable jurisdiction.

If You have any questions about this Privacy Policy or have any requests for resolving issues with your personal data while using Our services, please contact Us as soon as possible by emailing Our Data Protection Office at [JJKPPservice@biligames.com].

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.

This section applies to California residents covered by California Privacy Act ("CPRA"), formerly the California Consumer Privacy Act(“CCPA”).

Collection and Disclosure of Personal Information. Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

· Identifiers, such as your username, open ID / user ID, nickname, IP address, device ID operating system, device type and other device information, email address, your social media profile.

· Data of Use of the Service: such as gameplay data (such as game setting), in-game interactions, geolocation information.

· Commercial information about any transactions in our services. or via a third party such as what products were purchased and how much they cost.

We do not collect or disclose sensitive personal information specified in the CPRA. In the past 12 months, We have not sold Personal Information of California residents within the meaning of “sale” in the CPRA.

California law grants California residents’ certain rights and imposes restrictions on particular business practices as set forth below. As permitted by the CPRA, any request you submit to us is subject to an identification process (“Verifiable User Request”). We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the User about whom we collected personal information. To make a request, email us and respond to any follow up inquires we may make. If we cannot comply with a request, we will explain the reasons in our response.

Do-Not-Sell and share. California residents have the right to opt-out of our sale and sharing of their personal information. We do not sell personal information about residents who We know are younger than 16 years old.

Initial Notice. We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used. We will make this Privacy Policy available to Users online, in order to satisfy this requirement.

Requests to Delete. Subject to certain exceptions, California residents have the right to, at no charge, request deletion of their personal information that We have collected about them and to have such personal information deleted, except where an exemption applies. To send the request, please email to [JJKPPservice@biligames.com], and We will proceed with it within 30 days.

Right to correct. Subject to certain exceptions, California residents have the right to request correction of the personal information we have collected about them. You may request for the correction of your personal information.

Request to Know. California residents have the right to request and subject to certain exemptions, receive a copy of the specific pieces of personal information that We have collected about them in the prior 12 months and to have this delivered, free of charge by email, readily useable format that allows the individual to transmit this information to another entity without hindrance. To send the request, please email to [JJKPPservice@biligames.com] and We will proceed with it within 30 days. California residents also have the right to request that We provide them certain information about how We have handled their personal information in the prior 12 months, including the:

Ÿ business and/or commercial purposes for collecting and selling their personal information;

Ÿ categories of third parties/with whom we have disclosed or shared their personal information;

Ÿ categories of personal information that we have disclosed or shared with a third party for a business purpose; and

Ÿ categories of third parties to whom the residents' personal information has been sold and the specific categories of personal information sold to each category of third party.

We will respond to verifiable requests received from California residents as required by law.

Right to Non-Discrimination. The CPRA prohibits discrimination against California residents for exercising their rights under the CPRA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CPRA rights, unless doing so is reasonably related to the value provided to the business by the residents' data.

Financial Incentives. A business may offer financial incentives for the collection, sale or deletion of California residents' personal information, provided it is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent; we do not offer any such incentives at this time.

Retain. We retain each type of personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, to comply with a legal obligation, to resolve disputes, to prevent fraud, or to enforce an agreement.

You Rights Under California's Shine-the-Light Law. We do not share personal information collected online with unaffiliated third parties for their own direct marketing purposes and will not do so unless You agree to such disclosure. If you are a California resident and You still believe your information has been shared or You have general questions about how your information may have been shared, You may contact us by requesting a list of the third parties to which We have disclosed personally identifiable information about You for their own direct marketing purposes. You may make one request per year. In your request, please attest to the fact that You are a California resident and provide a current California address for your response.

By accepting and consenting to this Privacy Policy, You agree that We may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If You do not agree to this Privacy Policy, You must not access or use Our Services and We have the right to not provide You with access to Our Services.

If You are under the age of 21, You undertake that You have the consent of your parent or legal guardian to register an account on the Game and use the Game Services.

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.

In the event We fail to maintain the confidentiality of your personal information in the Game, We will notify You through the contact information provided by You or via the Game to minimize the impact of data breaches, to the extent required by local laws and regulations.

If You fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen (14) days of the date the relevant amended version of this Privacy Policy is made available , You will be considered as having accepted the changes and agreed to the new privacy policy. However, You may deleting your account or ceasing your use of the Game Services at any time, if You cease to agree with the amended Privacy Policy.

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).

If You are under the age of 18, please do not use Our Services except where your parent or guardian has provided consent

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.

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.

By clicking “accept”, You consent to the cross-border transfer of your information to any country or region where We have databases or affiliates and, in particular, the People’s Republic of China and Japan.

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 Our Services.

If You are under the age of 20, please do not use Our Services except where your parent or guardian has provided consent

To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, You shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the National Privacy Commission(NPC), damages and data portability. Before We can respond to a request to exercise one or more of the rights listed above, You may be required to verify your identity or your account details.

By accessing and/or using Our Services, You represent that You are at least 16 years of age or not under guardianship. If You are below 16 years old or under guardianship, before you access and/or use our Services:

• your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use Services,including opening an account in the name of a parent or legal guardian and overseeing all of your activities under that account; (ii) your compliance with this Privacy Policy; and (iii) ensuring that any of your participation will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If You do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, You must cease accessing the Services.

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you can submit “Privacy Request Form” or contact us by email to [JJKPPservice@biligames.com] . Our privacy experts who monitor this email address are also able to answer 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.

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.

International Data Transfer. By acknowledging the Privacy Policy, you consent to 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 China. If we transfer your data outside of Japan to a country that is not recognized by Personal Information Protection Commission as establishing a personal information protection system recognized to have equivalent standards the same in Japan, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the reasonable standard measures following the requirements of Section 1 of Chapter 4 in Japanese APPI. You may ask for a copy of such appropriate measures by contacting us. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.

Your Rights.You have a right to request disclosure of your personal data retained by us (“Retained Personal Data”) and purpose of use thereof, disclosure of records of third parties transfer, correction, addition, deletion, and discontinuance of the use and third parties transfer of the Retained Personal Data. To make a request concerning your rights above, please contact us by sending an email to Chief Privacy Officer(privacy@krafton.com). In special cases (i.e. request your rights through mailbox, etc.), we may demand a fee when you request your rights.

Act on the Consumer Protection in Electronic Commerce, Etc.	In an electronic commerce or a mail-order sale:· Records regarding labelling and advertising (6 months)· Records regarding execution or withdrawal of a contract (5 years)· Records regarding the payment of a price and the supply of goods and services (5 years)· Records regarding customer services or dispute resolution (3 years)
Protection of Communications Secrets Act	· Log records, IP address (3 months)· The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

Act on the Consumer Protection in Electronic Commerce, Etc.	In an electronic commerce or a mail-order sale:· Records regarding labelling and advertising (6 months)· Records regarding execution or withdrawal of a contract (5 years)· Records regarding the payment of a price and the supply of goods and services (5 years)· Records regarding customer services or dispute resolution (3 years)
Protection of Communications Secrets Act	· Log records, IP address (3 months)· The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

Act on the Consumer Protection in Electronic Commerce, Etc.	In an electronic commerce or a mail-order sale:· Records regarding labelling and advertising (6 months)· Records regarding execution or withdrawal of a contract (5 years)· Records regarding the payment of a price and the supply of goods and services (5 years)· Records regarding customer services or dispute resolution (3 years)
Protection of Communications Secrets Act	· Log records, IP address (3 months)· The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

You may 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 Retention. The personal information detailed in this Privacy Policy are required to be retained pursuant to the following laws:

Act on the Consumer Protection in Electronic Commerce, Etc.	In an electronic commerce or a mail-order sale:· Records regarding labelling and advertising (6 months)· Records regarding execution or withdrawal of a contract (5 years)· Records regarding the payment of a price and the supply of goods and services (5 years)· Records regarding customer services or dispute resolution (3 years)
Protection of Communications Secrets Act	· Log records, IP address (3 months)· The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

Your rights. 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.

Region in which the user is located	minimum user-age requirements
Brazil	18
Canada	14
European Economic Area	16
Indonesia	21
Japan	18
Malaysia	18
Philippines	18
Singapore	18
South Korea	14
Vietnam	16
Thailand	20
United States	13
United Kingdom	13