Privacy Policy

1st-impact co., ltd. (hereinafter, the “Company”) shall handle the information of all persons (hereinafter, the “Users”) who use the games and related online services provided by the Company (hereinafter, the “Service”) as follows.

1．Introduction

BY USING THE SERVICE, THE USER AGREES TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND CONSENTS TO THE PROCESSING OF INFORMATION THAT THE COMPANY COLLECTS FROM THE USER FOR THE PURPOSES DESCRIBED BELOW. PLEASE READ THIS PRIVACY POLICY CAREFULLY. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICE. The Company takes all safeguards required by law to ensure the safe handling of customers’ personal information. This Privacy Policy only applies to the games, platforms, other applications, websites, events, etc. (collectively, the “Service”) managed by the Company for which it is posted, displayed, provided, or presented. Upon using or accessing the Service by using, installing, registering, applying for the Service or taking any other methods, the User shall be construed as having agreed to this Privacy Policy.

2．Purpose of Use, etc.

In the provision of the Service, the Company will acquire and use this information within the scope necessary in order to fulfill the purposes stipulated in each of the following items. The type of information to be collected, processed or used may differ depending on the service used by the User. In addition, the information containing personal information collected by the Company during the course of the Service are outlined below. Failure to provide information may result in the inability to use the Service in part or their entirety.

1. Device information

Information to be acquired: Information concerning a PC, such as ID or OS version, which identifies the Steam account of the User
Acquisition method: Automatically
Purpose of use: To secure automatic online matching between the Users and to prevent use in situations that violate the Terms of Use of the Service.

2. Information on IP address

Information to be acquired: Information on the IP address that the User uses
Acquisition method: Automatically
Purpose of use: To connect the User with others to play online services of the Company

3. Information on purchases

Information to be acquired: Information concerning purchases of paid services within the Service
Acquisition method: Provided from the platform provider of the Service
Purpose of use: To respond to inquiries and to conduct surveys on trends concerning use

4. Information on inquiries

Information to be acquired: Information provided on the inquiry form, including information on the User’s ID for the Service and smartphone in use, matters for confirmation additionally requested from the Company, and email address
Acquisition method: Data entry by the User (*automatically by mailer for email addresses only)
Purpose of use: To respond to inquiries and to confirm the identity of the User

5. In-service information

Information to be acquired: Information concerning the usage situation of the Service (access time and date and history, etc.)
Acquisition method: Automatically
Purpose of use: To respond to inquiries and to conduct surveys on trends concerning use

6. Personal Information

Information to be acquired: Information that can be used to identify the individual User by the Company from among their name, in-game username, email address, other ID information, telephone number, photograph, or other images (including avatar image), date of birth, gender, address, credit card information, and location information.
Acquisition method: Provided from the User
Purpose of use: To provide the Service to the User and notify the User of changes to this Privacy Policy and other terms and conditions, communicate with the User regarding their purchases, and notify the User of the latest service or application updates

7. Statistical Information

Information to be acquired: IP address, UUID (Universal Unique Identifier), social network ID, game ID, cookie data, and advertising ID
Acquisition method: Provided from the platform provider of the Service
Purpose of use: To provide the Service to the User, to store game data in profiles across multiple devices, to improve the stability of the Service, to conduct market research and information analysis to provide services that are in the interests of the User, to deliver advertisements (including confirmation of the fulfillment of clicks and other advertising performance conditions), and to provide the User with the information on third-party products, services and contents that may be of interest to the User

8. Information on Website Usage

Information to be acquired: Information on the device used to access the website (model, OS version, IP address, language, carrier such as provider and related information), information on the functions of the device (including but not limited to notifications), frequency of use of the website and other usage information, and information on traffic to the website
Acquisition method: Provided from the platform provider of the Service
Purpose of use: To maintain and improve the performance, stability, security, and convenience of the website, and to measure the effectiveness of advertising and marketing campaigns For the purposes of the GDPR, the classification of legal bases in relation to residents of the European Economic Area and the United Kingdom is as follows. If consent is the legal basis, the User can withdraw their consent in the future by contacting the Company. Such withdrawal will not affect the lawfulness of the processing prior to withdrawal.

Provision of the Service to the User, confirmation of the User’s identity, prevention of the use of the Service in a manner that violates the Terms of Use of the Service, responses to inquiries, notifications to the User (including, but not limited to, changes to this Privacy Policy and other Terms of Use, communication regarding User purchases, and notification of updates to the latest services and applications), storage of game data in profiles across multiple devices, and improvements to the stability of the Service

Confirmation of the User’s identity, prevention of the use of the Service in a manner that violates the Terms of Use of the Service, investigation of trends related to use, implementation of market research and information analysis to provide services that meet the interests of users, distribution of advertisements (including confirmation of clicks and other advertising performance conditions), maintenance and improvement of website performance, stability, security, and convenience

Market research and information analysis to provide services that are in the interests of users, distribution of advertisements (including confirmation of clicks and other advertising performance conditions), maintenance and improvement of website performance, stability, security, and convenience, notification of information on third-party products, services, and content that may be of interest to users

3．Provision to Third Parties

(1) Within the purposes and scope set out in this Privacy Policy, the Company may share the personal information of Users with its affiliates and third parties who process personal information (e.g., credit card processors, email service providers, software or service developers, user account certifiers, cloud storage server administrators, delivery companies, payment processors, campaign sponsors, customer service providers).
(2) The Company may include tools managed and provided by a third party contracted by the Company that enable the Company or the third party to analyze User information within the Service. This information may include UDIDs, device identification information, operating system information of the device used, communication service provider information, IP address, and connection start and end times to the Service. However, such third parties will use the information in an anonymized and aggregated form and not for any purpose other than analyzing the user information.
(3) The Company may be compelled to disclose the User’s personal information by law, legally binding court orders, or orders from investigative agencies or supervisory authorities issued through due process. In addition, the Company may disclose personal information when it is necessary to protect the rights and property of a corporation such as the Company or an individual, or when the Company deems it necessary to disclose it for important public purposes such as national security.
(4) In the event of a merger, acquisition, business transfer involving the sale of all or part of the Company’s assets, bankruptcy, corporate reorganization, liquidation, or similar procedures, the Company may transfer the User’s information to a third party that succeeds the Company’s assets and/or rights.

4．Secure Management of Information

The Company will take action and supervise as necessary and appropriate to prevent the divulgation, loss and/or damage, etc., of personal information by the Company’s officers and/or employees as well as outsourcing partners in the case of outsourcing the handling of personal information externally. However, no data transmission over the Internet is 100% secure. As such, the Company does not guarantee that unauthorized access, hacking, data loss, or tampering will not occur. The User is responsible for all information that they transmit through the Service.

5．Storage Period

The Company will not retain the personal information of the User for longer than necessary to achieve the purpose of use for which it was collected. Personal information that is no longer needed will be deleted from the Company’s systems and other recording media, or the information will be appropriately anonymized so that it cannot be identified. However, this does not apply to cases where storage is necessary to comply with legal obligations.

6． Requests, etc., for Personal Information

When a request is made by the User concerning the correction, addition, deletion, suspension of use and/or erasure of their personal information, or the cessation of provision to third parties, or notification of the purpose of use, the Company, after having verified the identify of said User, will respond. However, if all of their information is deleted, the User’s account may be deactivated. The Company may keep archival copies of the User’s records for our legitimate interests.

7． External Transmission and Use of Data Acquisition Modules

The Company may use the following third-party data acquisition modules that are independent of the functions of the Service in order to investigate trends related to the provision and use of the Service and to measure the effectiveness of appropriate advertising for users. The recipients, subject information, and purposes of use of the information are as follows.

●Google Analytics

Data recipient: Google LLC Subject information: User ID, advertising ID and device ID for the Service, in-app behavioral data, behavioral data concerning in-app purchases, device information, and information concerning OS and settings (language settings, time zone, etc.) Purpose of use: To measure and analyze the effects of advertising and analyze user trends for improving service quality For more information on the terms and conditions regarding Google Analytics, please refer to the Google Analytics Terms of Service and Google’s Privacy & Terms. https://marketingplatform.google.com/about/analytics/terms/us/ https://policies.google.com/technologies/ads

8. Suspension of Transmission and Deletion of Personal Information

The Service does not provide a method of stopping the automatic transmission of personal information on browsers. Therefore, when using a website related to the Service, the administrator of the browser may collect personal information about the User’s activities on the website. If the User does not wish for personal information to be transmitted automatically, please uninstall the Service or disable the automatic transmission function at the User’s own responsibility. In addition, the Service does not provide a method for deleting personal information from the Company’s server.

9. Use of Cookies

The Company may use cookies to provide better services to the User on the website provided by the Company as the Service. This does not mean that the Company collects personally identifiable information nor does it infringe on the privacy of the Users. If the User does not wish to receive cookies, the User can refuse to accept cookies using the settings in the User’s browser.

A cookie is a piece of information that is sent from the server computer to the User’s browser and stored on the hard disk of the computer used by the User.

10. International Transfers of Information

The Company may transfer information about the User to its affiliates or third parties located outside of the User’s country of residence. If the User is a resident of the European Economic Area, the United Kingdom, or any other country/region, the laws and regulations regarding personal information in the destination country or region may differ or may not be as strict as the laws and regulations of the region in which the User resides. The User also consents to the use of the User’s information in the destination country or region in accordance with this Privacy Policy.

11. Policy on Children

The Service is not directed at children under the age of 13, and the Company does not knowingly collect personal information from children under the age of 13 or permit them to use the Service. If the Company becomes aware that it has collected personal information from a child under the age of 13, the Company will delete that information from its systems or other recording media as soon as possible.

If the User is a resident of the European Economic Area and the United Kingdom, the User may have the following rights:

The right to obtain from the Company the necessary information about its data processing activities concerning the User (Articles 13 and 14 of the GDPR);
The right to obtain confirmation from the Company about whether personal data concerning the User is being processed and, if so, access to the User’s personal data and related information (Article 15 of the GDPR);
The right to rectify and complement inaccurate personal data (Article 16 of the GDPR);
The right to request the deletion of personal data without undue delay if certain conditions are met (Article 17 of the GDPR);
The right to request the restriction of the processing of personal data if certain conditions are met (Article 18 of the GDPR).
The right to object to the processing of personal data concerning the User if certain conditions are met (Article 21 of the GDPR).
The right to receive personal data in a structured, commonly used and machine-readable format and the right to transmit such data to another controller without hindrance from the Company if certain conditions are met (Article 20 of the GDPR); and
The right not to be subject to automated decision-making (including profiling) based on the processing of personal data, which has legal or similar effects if certain conditions are met (Article 22 of the GDPR).

13. Rights of Residents of California

California Civil Code Section 1798.83 permits residents of California to request certain information regarding the disclosure of their personal data to third parties for direct marketing purposes. The Company does not share personal information for the direct marketing purposes of third parties. The User has the right to know and access information about the categories and specific information the Company has collected about the User, as well as the categories from which such information was collected, the purposes for which such information was collected, and the categories of third parties with whom the Company shares such information. The User also has the right to know whether the Company has sold or disclosed the User’s personal information. The User may request a copy of the personal information the Company has collected, and upon request, the Company will provide this information by electromagnetic means. The User has the right to request information about the Company’s transfer or disclosure of the User’s personal data to third parties for business purposes. Residents of California have the right not to be discriminated against for exercising these rights. If the User wishes to exercise one or more of these California rights, please contact the Company using the contact information provided in Article 15. The User may also designate an agent registered with the California Secretary of State to contact the Company on behalf of the User. The agent must have written permission to contact the Company on behalf of the User. Where verifiable, the Company will match the identification information the User provides with the personal data the Company already holds. However, if the Company is unable to verify the User’s identity from the information the Company already holds, the Company may request additional information.

14. Revisions

The Company may revise these regulations in part or their entirety. In case of material changes, the Company will file notice of publication on its corporate website along with the date the updated Privacy Policy takes effect. If the User continues to use the Service after the Company posts and publishes the updated Privacy Policy or notifies the User of any changes, the User shall be deemed to have agreed to the updated Privacy Policy. If you do not agree to updated Privacy Policy, please stop using the Service, etc.

15. Inquiries

Inquiries concerning personal information can be directed to: support@geareqd.games

Established on April 22, 2024

2024-05-27