Gravity Game Vision Limited

PRIVACY POLICY

(Effective Date: August 7, 2025)

Gravity Game Vision Limited (“Company”, “we”, “us” or “our”) maintains this Privacy Policy (“Privacy Policy”) that summarizes our policies and processes on how we collect, use, disclose, transfer and store your personal information. We are headquartered in Hong Kong and publish and distribute Our Services (to be defined below) globally from there. We recognize and value the privacy of people (“you” or “user”) who use Our Services. If you have any questions, please reach out to us as described in Section 12 Contact Us.

We may translate this Privacy Policy into other languages. In the event of any inconsistency between the English version and a translated version, the English version shall prevail, subject to applicable laws and regulations..

What are Our Services?

We use the term “Our Services” to collectively describe any of the products or services that directly link to this Privacy Policy. These include, for example:

• Gaming product RO 3;
• Official website of RO 3;
• Events, activities or any other initiatives where this privacy policy is posted.

Please read this entire Privacy Policy and other agreements that apply to the services you use, and confirm you understand and agree to them, before using those services. By accessing or using Our Services you acknowledge that you have read, understood, and accepted this Privacy Policy. If you do not agree with any terms of this Privacy Policy, you should immediately stop using Our Services.

This Privacy Policy informs you of the following information:

1. What Data We Collect and Process
2. Why We Collect and Process Your Personal Information
3. Legal Basis of Our Data Collection and Processing
4. Advertisements and Your Choices
5. Cookies and Similar Technologies
6. Information Sharing
7. Data Retention
8. Your Rights and Choices
9. Securing Your Data
10. Children’s Protection
11. Changes to Privacy Policy
12. Contact Us
13. Supplemental Terms – Jurisdiction-Specific

1. WHAT DATA WE COLLECT AND PROCESS

Personal information means any information relating to an identified or identifiable natural person, such as nickname, phone number, email address, contact address, location, and social media accounts.

A. Data We Collect and Process (either directly from users or through a third party)

1. Contact information and identifiers / account registration information.

When you create an account, we may collect your username, email address, mobile phone number, password, verification code (if any), and Open ID/Union ID, to help you create and manage the account for using Our Services, to provide game login services, and for other purposes set forth in Section 2 Why Do We Collect and Process Your Personal Information and Section 13 Supplemental Terms – Jurisdiction-Specific of this Privacy Policy.

2. Service account information.

We may also collect account information related to Our Services, such as your age (if any), nickname, avatar, gender (if any), username, account ID and account level.

3. Date of birth.

Where applicable, you may need to provide us with (a) your date or month of birth for age verification or other screening purposes; and (b) your birthday when you apply for birthday gifts or other benefits available on Our Services.

4. Connected social media account information (third party).

If you choose to log in to Our Services via your social media account(s), we may receive your social media account information (including your nickname, avatar and other information authorized by you) from third-party social media providers, such as Line, Facebook, X, Discord, Google, Apple, Huawei. Such information obtained from third-party social media providers may be added to your account information.

5. Personal profile information.

You can choose to create your personal profiles (where available) in Our Services by setting a nickname, creating your personal signature (if any), uploading your avatar, social media platform account, Discord username, and other information depending on the setup of Our Services.

6. Game data.

We process information about in-game services and functions, including your game character ID, gameplay status, progress, and usage statistics to provide you with feedback and information, and for other purposes set forth in Section 2 Why Do We Collect and Process Your Personal Information and Section 13 Supplemental Terms – Jurisdiction-Specific of this Privacy Policy.

7. Chat data.

If you use the in-game chat function, we may process the communication record. For some of Our Services, we may apply encryption – and in certain services, end-to-end encryption – to protect your data.

8. User generated content.

We process all content generated by users, including information that you post on Our Services, all feedback you provide to us, information that you post, comment on, or follow in any of Our Services.

9. User service information.

When you seek our technical or customer service support, or exercise any of your legal rights as the data subject, we may collect the information that you provide in communications with our support team.

10. Survey information.

We will collect your survey responses, if you participate in our surveys.

11. Activity participation information.

Suppose you agree to participate in any events organized by us. In that case, we may collect your participation information, including your name, user ID, email address, phone number, nickname, country/region, age (if any), gender (if any). Where you win any prizes, you may also need to provide us with your mailing address or certain tax information for us to send you the prize. Your event participation information may be added to your account.

12. Advertising information.

We may collect advertising ID (including Google Advertising ID, IDFA), Device ID (including IDFV, OAID, Android ID, PC tracking ID) and other select device information, and store this information with your profile to deliver advertising that may be relevant to your interests and track the success of our advertising and marketing programs. Additionally, after taking appropriate technical security measures (such as encryption and hashing) to de-identify or pseudonymize your email address (including email address collected from third party social media providers when you log in via your social media account), we may use your de-identified or pseudonymized email address to track the success of our advertising and marketing programs.

13. Payment data.

If you purchase in-game items, we may collect your payment data and purchase history in order to maintain your transaction history record and process your purchase(s) and related activity, which may include your name, transaction date and time, transaction order number, currency, transaction amount, payment channel, and product(s) purchased. But we do not collect your credit card or bank account information when you make in-app payments.

14. Inferences.

We may make certain inferences, such as your preferences and interests, drawn from any of the information we collect.

15. Other information subject to specific notice.

For some websites, apps, or services provided by us, we may collect additional information beyond the above listed information. We will develop individual privacy notices to inform you how we process your personal information when you use that specific service. Such individual privacy notices will prevail in terms of the personal information processed for those individual services.

B. Data We Automatically Collect

1. Device-related data.

This includes data such as Internet Protocol (IP) address, device identifiers, country code and language, online ID, Advertising ID, device ID, device manufacturer, device name, device type/model, MAC address, User-Agent (such as browser type), IP address, IMEI data, CPU and GPU data, dashboard data, storage, operation system version and language, microphone data, time zone, screen DPI, device resolution, device mode/status, device and browser settings and configurations, memory data, and graphics card model.

2. Cookies data.

Information collected through cookies and similar technologies.

3. Data related to bugs, errors, crashes and diagnosis.

This includes registration/login time, game version, user ID, stack trace, crash reports, reason for suspension, duration of suspension, suspension type and abnormal process data.

4. Security related data.

This includes installed app names, system startup time, app install and update time, request and referral URLs, system activity details, game-related plug-in and runtime data, network status and information, data related to external plugin programs, process data, SD card cache, APK data, APK name and version, SD card target file, host file, screenshots of gameplay (if you are suspected of cheating behavior), root/simulator status, sensor data, critical system library data, gameplay data, and details of incident.

5. Services interaction and/or usage data.

This includes the pages and other content you view, the URL of the website from which you came to our sites, any content you post, the dates and times of your visits, the types of content you search for, view, or interact with, the features you use, the actions you take, the people or accounts you interact with (if any), and when, how often, and for how long.

6. Information about your interactions with others.

We also capture and use the content, communications, and information you provide when you interact with others.

7. Data shared with us by third parties.

This includes (i) data we receive from third-party applications when you link them to Our Services, such as when you make a third-party login via Facebook, X, Google, or Apple, and (ii) third-party data for message push, security assurance, and statistical analysis purposes.

Note: In specific cases, we may collect other personal information apart from the categories stated herein based on your consent or other legal bases. When this occurs, we will, where required under applicable laws, provide more information about any change to the way or purpose of our collection or processing which are different from or not clarified in the details in this Privacy Policy.

In order to better provide you with a complete gaming experience, we may merge our collected personal information with data from third-party contractors in order to update your profile (e.g. the information of your connected third-party accounts), perform market analysis, or otherwise as set forth in Section 2 Why Do We Collect and Process Your Personal Information and Section 13 Supplemental Terms – Jurisdiction-Specific of this Privacy Policy, with your prior consent or where we have other legal grounds permissible under applicable laws.

C. Sources of Personal Information

We have collected personal information from different sources and in various ways, including the following categories of sources:

• You/Your Devices: You or your devices directly.
• Users: Other users of Our Services.
• Affiliates (to be defined below).
• Service Providers.
• Advertising Networks.
• Analytics Providers.
• OS/Platform Provider: Operating systems and platforms.
• Social Networks.
• Business Partners.
• Publicly Accessible Sources.
• Inferences: Data we infer or generate about users from other data we collect.

“Affiliates” in this Privacy Policy means an entity that directly or indirectly controls, is controlled by, or is under common control with Gravity Game Vision Limited.

2. WHY WE COLLECT AND PROCESS YOUR PERSONAL INFORMATION

In order to provide Our Services to you, we collect and process your personal information for one or multiple purposes described below and/or in Section 13 Supplemental Terms – Jurisdiction-Specific:

1. facilitate your use and access to, or to restrict your use or access to, Our Services;

2. allow you to create account that enables you to manage your account and personal profile;

3. to facilitate our age verification process (if any);

4. to facilitate your downloading our games, including any related troubleshooting;

5. provide you with the services required by you and perform our contractual obligations to you;

6. analyze and manage Our Services for system administration, user service, security, fraud detection, checking the authenticity of an account owner, archival or backup purposes;

7. 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;

8. develop new services or products and improve the user experience;

9. verify and confirm payment, ensure payment security, maintain transaction history record and resolving subsequent payment disputes;

10. deliver advertising that may be relevant to your interests and track the success of our advertising and marketing programs;

11. communicate with users (including by sending text messages and/or push notifications) and take action against violations;

12. personalize your experience;

13. provide you with customer service support;

14. create contact with other users of Our Services;

15. facilitate your participation in user events;

16. keep you up to date with the latest product announcements, and provide other information about Our Services;

17. provide software verification, upgrades and administration, and notify of special events;

18. participate in our surveys, events or activities;

19. prevent malicious or offensive information in order to ensure a harmonious and healthy online environment in Our Services;

20. to prevent certain words in your signature, nickname, or chat data from offending or distressing others within Our Services;

21. ensure security and stable operations, such as account recovery, binding, or rebinding, user account system operation, account security risk review and improvement, account security reinforcement, real-time account security risk monitoring and protection, and account fraud prevention;

22. provide a fair gaming environment, including prevent cheating;

23. improve the functionality and quality of Our Services;

24. fulfill our obligations under applicable laws and regulations, respond to requests of government authorities;

25. establish, exercise, or defend legal claims;

26. analyze, profile, segment, merge or update all collected data (regardless of an aggregated or individualized manner) for the purposes of improving service quality and providing a better experience;

27. protect the integrity, information safety, and financial security of Our Services or users, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of Our Services;

28. to conduct user research;

29. track your process across our websites and applications to verify that you are not a bot and to optimize Our Services; and

30. for any other purposes for which we provide specific notice at the time the information is collected.

For the purposes mentioned above, our Affiliates may be commissioned to process your information, provided that such Affiliates comply with this Privacy Policy.

3. LEGAL BASIS OF OUR DATA COLLECTION AND PROCESSING

We are required to disclose the legal basis for processing your data under certain applicable laws, including the GDPR. To the extent that such laws apply to you, we rely on the following legal bases to collect and process your personal information:

1. Necessary for us to comply with our service agreement.

2. Conducted with your consent, especially when legally required (you may email us at biz@gravitygame.hk at any time to withdraw your consent).

3. Necessary for us to perform our legal obligations.

4. Necessary for us to protect your important rights and the important rights of others (unless there is a conflict of interest between these rights and your rights).

5. Necessary for our legitimate interests and those of third parties, including our rights to provide innovative, and secure services to our users.

4. ADVERTISEMENTS AND YOUR CHOICES

To provide personalized advertisements, you acknowledge and agree that we may collect and process your data to:

1. deliver, target and improve our advertising; and/or

2. improve advertising and other marketing and promotional activities.

We, or where allowed under applicable law, our authorized contractors, may deliver advertisements, marketing or promotional communications. If you do not wish to receive such information, you may request that we or our contractors remove your data from the contact list by emailing us at biz@gravitygame.hk.

5. COOKIES AND SIMILAR TECHNOLOGIES

In order to measure the effectiveness of Our Services, we may use cookies, which are small text files for added functionality or for tracking site usage. We may use cookies and/or authorize a third-party’s tracking-utility, from time to time, to (a) log your IP address in determining the path that users take on our sites and identifying repeat users of our sites, (b) collect the websites or sources that linked or referred you to Our Services, (c) collect technical data about the devices and software you use to access Our Services, the operating system of your devices, and other similar technical data and/or (d) collect personal information about your online activities over time and across different websites or online services.

If you do not wish to accept cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser permits.

We use the cookies, web beacons and similar technologies to personalize your experiences on Our Services and for various other purposes, including:

1. remember you: to help us identify you as a registered user and keep the preferences or data that you have previously provided;

2. analyze how you use Our Services: to help us understand what visitors (including users) are doing on Our Services, or what pages or sections are most popular, and to tell if you have opened or acted upon our email messages or newsletters;

3. deliver advertising: to help us provide you with advertising that we believe is relevant to you or of interest to you, on the basis of the data you provide; and

4. other related functions or purposes mentioned in Section 2 Why Do We Collect and Process Your Personal Information and Section 13 Supplemental Terms – Jurisdiction-Specific.

We or our authorized contractors may also use cookies and similar technologies to provide and personalize services, prevent fraud and fulfil other purposes mentioned above. Please note you may be able to disable cookies in your browser settings, or, depending on your jurisdiction, through our cookie settings. However, if you do so some of Our Services may not function properly.

6. INFORMATION SHARING

We may share your information with our Affiliates for the purposes indicated in Section 2 Why Do We Collect and Process Your Personal Information and Section 13 Supplemental Terms – Jurisdiction-Specific under this Policy. In addition, we may share your information with other parties in the following situations. You acknowledge that you have foreseen these disclosures when you provide your personal information.

A. Other In-Game Users of Our Services

Other users may also see your displayed data (including your nickname, user ID, achievements, levels, and other character information) and read the messages you have posted on or through Our Services. You acknowledge and agree that Our Services may also include message boards, communities, forums, and/or other chat areas, where users may exchange ideas or communicate with other users, and that any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time on or through Our Services.

B. Competent Authorities

We may provide a certain portion of your personal information to governmental authorities as so requested according to applicable laws and regulations, or where it is in the public interest to do so. Other than where we are required by applicable laws and regulations, we reserve the right to disclose your personal information in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if we reasonably believe that (a) you are violating any other agreements between you and us, such as the Terms of Service, this Privacy Policy, or otherwise damage us; (b) you are infringing third-parties’ rights and interests (including but not limited to intellectual property rights); or (c) it is necessary to prevent fraud or other illegal activities.

C. Merger, Acquisition, Reorganization, Bankruptcy, New Owner

We may, in accordance with applicable laws, transfer your information to third parties if we:

1. 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

2. 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.

D. Service Providers

We may work with the following types of third-party service providers to help us provide services and functionalities to you:

1. Social networking portals (who may be considered our partners in some countries) who provide login and/or content-sharing service to and in Our Services;

2. Logistics service providers who provide shipping services such as delivering physical prizes to users;

3. Providers and carriers to send authentication messages;

4. Providers that carry out surveys (if any);

5. Payment service providers who provide payment services, such as assisting us in operating services, facilitating users’ payment, and maintaining a record of the users’ transaction history;

6. Advertising service contractors who provide marketing and advertising activities, including showing you ads that we think may interest you, conducting the programs, tracking the success, and analyzing the effect thereof;

7. Content screening service providers;

8. Data storage service providers;

9. Analytics service providers (if any);

10. Technology or operation service provider;

11. Service providers we engaged to ensure safety, security, or compliance with laws, including to (i) enforce our terms and conditions and other agreements, and investigate any potential violations; (ii) detect, prevent or otherwise address security, fraud or technical issues; or (iii) protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (for example, by exchanging information with other companies and organizations for the purposes of fraud protection); and

12. Other contractors, if any, for the purpose of providing Our Services to you.

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 Our Services.

Additionally, such service providers may collect or receive additional data about you. For example, when purchasing in-game items, you will be required to provide additional data to third-party payment service providers, such as credit card number, expiration date or security code. Such third-party payment service providers may collect, process, and retain your data to process payments and resolve subsequent payment disputes and inquiries. We may also receive, process and store some of the information provided by you or such third-party payment service providers to confirm payment, record purchase history, or protect our legitimate interest when resolving subsequent payment disputes and inquiries. Notwithstanding the foregoing, if you make any payments by using these services, your payment details are fully handled by the relevant payment service provider, and we do not receive or process any of your actual payment details such as credit card number, expiration date or security code. In these cases, we only keep the data concerning transaction date, amount, currency, and products or services purchased.

F. Business Partners

We occasionally run collaborations and special events with our business partners. These events may be run locally or globally, online or offline. If you participate in these special events, your personal information may be shared with these business partners in order to carry out the event, deliver the prizes, or follow up on the events which you opt in. When specific third parties are involved in collecting data, please refer directly to their privacy policies on their official websites and learn more about their data processing practices.

G. Affiliates

Our Affiliates who process your personal information solely for the purpose of providing Our Services to you. All of our Affiliates may only use your personal information in accordance with this Privacy Policy.

7. DATA RETENTION

We will keep your data only for as long as your account is active or only for as needed to provide you with Our Services unless deleted in accordance with your request or where we are required to do so under applicable law. The locations of servers for Our Services include one or a combination of the following locations:

• Europe
• USA
• Singapore

You acknowledge and agree that your data will be collected and processed on our servers which may not be located in your country/region of residence and can be accessed by our support, engineering and/or our Affiliates around the world. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws and regulations.

Where necessary for the purposes mentioned in Section 2 Why Do We Collect and Process Your Personal Information and Section13 Supplemental Terms – Jurisdiction-Specific of this policy, we may transfer your personal information to other parties, including those in Section 6 Information Sharing under this policy, which may involve the cross border transfer of data to other countries. In doing so, we will ensure that your personal information receives the appropriate level of protection in compliance with the applicable laws and regulations.

If you request to remove or delete your personal information, please note that we will continue to retain your data for the longest time permitted by applicable laws and regulations, to perform our legal obligations, resolve disputes, or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination or suspension of some of Our Services.

Where required by law, we will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where the applicable laws and regulations provide for longer storage and retention period. Upon the expiration of such period, your personal information will be deleted, or anonymized, in accordance with applicable laws and regulations.

8. YOUR RIGHTS AND CHOICES

Some jurisdictions’ laws grant specific rights to users of Our 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 to whom we disclose it. You can access the personal 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 any 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 Section 2 Why Do We Collect and Process Your Personal Information and Section 13 Supplemental Terms – Jurisdiction-Specific. 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 any of your personal information we hold that is inaccurate.

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your account. 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) but we will let you know if that is the case.

Restriction of Processing to Storage Only

You may have the right to require us to 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 defense of legal claims or for the protection of others.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us 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. 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 Our Services for maintenance, security, privacy or administrative-related communications). There are essential system and service-related announcements and you may not opt out of these notifications, which are not promotional in nature.

Advertising

We will only send marketing messages to you if we have your consent. You may choose to stop receiving marketing messages from us by using the unsubscribe option in the message or contacting us.

9. SECURING YOUR DATA

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 as part of Our Service or otherwise via the Internet; any transmission is at your own risk.

Please be aware that advertisers or websites with links to or from Our Services may collect personal information about you. This Privacy Policy does not apply to such third-party services, and cannot control the activities of those third parties. We highly recommend that you read the privacy policy of such third parties which you may be directed to before providing any personal information.

We also, to protect against data loss or destruction, have data recovery measures and emergency plans in place that are regularly tested, implement backup methods such as tape backup and data mirroring, and physically separate backup data.

10. CHILDREN’S PROTECTION

Children must not use Our Services for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 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 in the table below, you should refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

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, please contact us.

Region in which the user is located (if applicable)	Minimum age of the user
Algeria	19
Argentina	13
Australia	18
Bangladesh	18
Brazil	18
Cambodia	18
Canada	13
Colombia	18
Egypt	18
European Economic Area	16
Hong Kong	18
Indonesia	18
Japan	18
Kazakhstan	18
Kuwait	21
Macau	18
Malaysia	18
Mexico	18
Morocco	18
Myanmar	18
New Zealand	16
Nigeria	13
Philippines	18
Qatar	18
Russia	14
Saudi Arabia	18
Serbia	15
Singapore	13
South Africa	18
South Korea	14
Sri Lanka	18
Switzerland	14
Taiwan	20
Thailand	20
Tunisia	18
Türkiye	18
United Arab Emirates	21
United Kingdom	13
United States	13
Vietnam	16

11. CHANGES TO PRIVACY POLICY

We may occasionally update this Privacy Policy, including to align with changes in Our Services or comply with updated laws and regulations. We encourage you to check this Privacy Policy for updates periodically. Where necessary or required under law, we will notify you of any updated terms to obtain your consent again or allow you to exercise your rights. If you have any questions or concerns about our privacy practices, please reach out to us using the details provided in Section 12 Contact Us. Your continued use of Our Services shows that you acknowledge how we collect, handle, and use your personal information according to the revised Privacy Policy.

12. CONTACT US

If you have any requests, concerns, questions about us, this Privacy Policy or how we process your personal information, or you want to make any complaints or exercise your data subject rights, please contact us as soon as possible by emailing us at biz@gravitygame.hk or via the address below:

Company name: Gravity Game Vision Limited

Address: F, 25/F, COS Centre, 56 Tsun Yip Street, Kwun Tong, Kowloon, Hong Kong

13. SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Brazil

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 as set out in Section 12 Contact Us. This may affect your access or use of Our Services.

If you are under the age of 18, you should not use Our Services for any purpose without first obtaining parental or 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 us if you believe we have any personal information from any children under the age of 18 without such parental or guardian consent – we will promptly investigate (and remove) such personal information.

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal information, including, disclosing to third parties, to the extent provided by this Privacy Policy.

EEA and UK

If you are in the European Economic Area (EEA) or the United Kingdom (UK), the following additional information applies to you in addition to the Privacy Policy set out above.

Legal basis for processing your personal information

Our legal bases for collecting and using the information described in Section 1 What Data We Collect and Process for the purposes in Section 2 Why We Collect and Process Your Personal Information of our Privacy Policy above are:

• To establish and perform our contract with you (i.e. our Terms of Service) and to provide Our Services;
• For our or our partners’ legitimate interests, where those interests are not overridden by your rights and freedoms, e.g. to protect our legal rights, to pursue or defend legal claims, to improve Our Services;
• Consent, where obtained separately;
• For compliance with our legal obligations under applicable laws and regulations;
• To protect our or your vital interests or those of another person (for example, another player), e.g. against fraud and violations of our terms.

While we typically do not collect sensitive or special category personal information, where we do this, it will be on the grounds of explicit consent or other applicable lawful basis.

Where we rely on a legitimate interest for the processing of your data, we have performed a legitimate interest assessment to determine whether our interests outweigh your rights and freedoms in the processing taking place.

You can obtain more information about this balancing test by using the contact details in Section 12 Contact Us.

If you have questions, need further information about the legal bases for processing your personal information, or want to withdraw your consent, please see Section 12 Contact Us in the Privacy Policy above.

Cross-border data transfer

As a global company, we may transfer your personal information to our Affiliates, third-party service providers and partners that operate around the world, which are located in countries other than the country in which you are resident (e.g. Singapore). These countries may have data protection laws that are different to the laws of your country.

Where we transfer your personal information to countries and territories outside of the European Economic Area and the UK, which have been formally recognized as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission, where applicable. Where the transfer is not subject to an adequacy decision, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. The safeguards we use are the European Commission’s Standard Contractual Clauses as issued on 4 June 2021, including the UK Addendum, and/or the UK International Data Transfer Agreement permitted under Article 46 of the UK GDPR. This is how transfers of personal information between us and other companies will be safeguarded. All companies are required to protect personal information that they process from Europe in accordance with European Union data protection law. Transferred personal information includes basic information such as your name or contact information such as your email address.

When we transfer your personal information internationally, we comply with relevant laws and regulations, and we enter into Data Processing Agreements (DPA) or Data Sharing Agreements (DSA) with all third-party partners (data recipients) with whom we exchange data. These agreements include limitations on the purposes of personal information processing, implementation of security measures, and cooperation obligations for exercising your rights, incorporating appropriate safeguards such as European Union Standard Contractual Clauses (SCC). This ensures that your data receives a high level of protection even in the countries to which it is transferred.

Children’s Notice

Our services are not marketed to, or intended for, children. For Our Services, Children refers to anyone who are (a) under the age of 13 years old or, if older (b) between 13 and 18 years old but can not give valid digital consent to processing of their personal information under applicable data privacy laws.

We strive to follow the different minimum age guidelines set by the laws of individual regions when determining the age at which children can access certain features of Our Services. Children are not permitted to use Our Services, and we do not knowingly collect any personal information from children. Though Our Services are not intended for children as the primary audience, we may collect age information before allowing a user to proceed for certain services (if applicable). If we learn that we have inadvertently gathered personal information about a child that is not subject to an exemption under applicable privacy law, we will take measures to promptly remove that information from our records.

Data Protection Supervisory Authority

To lodge a complaint with your national or regional data protection supervisory authority, please contact the competent authority.

Data Sharing under the Digital Markets Act (“DMA”)

This clause is dedicated to outlining our data sharing practices in compliance with the European Union’s Digital Markets Act (“DMA”) and is specifically relevant to users located in the European Economic Area. To enhance service quality and offer personalized user experiences, we may share data with third-party service providers designated as “Gatekeepers” under the DMA. This involves transferring user information, as described within this Privacy Policy, for purposes including advertising and service optimization.

DPO Information

EU:

For EU Residents: Please contact our EU Representative at EURep@gravitygame.hk. Alternatively, they can be reached by post (The DPO Centre Europe Ltd, Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2, Ireland) or +353 (0) 1 631 9460.

https://www.dpocentre.com/contact-us/

UK:

For UK Residents: Please contact our UK Representative at UKRep@gravitygame.hk. Alternatively, they can be reached by post (The DPO Centre Ltd, 50 Liverpool Street, London, EC2M 7PR United Kingdom) or +44 (0) 203 797 1289.

https://www.dpocentre.com/contact-us/

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 object 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.

Indonesia

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 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use Our Services.

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

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 consents 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 consents.

Japan

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 Our Services.

By clicking “accept”, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or Affiliates and, in particular,tothe jurisdictions specified inSection 7 Data Retention.

Some of the personal information we collect or process may include “special care-required personal information” (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contactusas set out inSection 12 Contact Us.

Macau

You have the right not to provide your personal information. However, as a result, we may not be able to provide Our Services to you. As a Macau 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

If you agree to thisPrivacy Policy in order for a minor to access and use theService, you hereby consent to the provision of personal information of the minor to be processed in accordance with thisPrivacy 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.

Right of correction: You may request for the correction of your personal information.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details in Section 12 Contact Us. However, this may affect our provision of Our Services to you.

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.

Philippines

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.

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

• collecting and processing your personal information as described in Section 1 What Data We Collect and Process and Section 2 Why We Collect and Process Your Personal Information;

• sharing your personal information with third parties, Affiliates, and a third party that acquires substantially 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 Section 7 Data Retention.

Singapore

By continuing, you consent to the cross-border transfer of yourinformation to any country where we have databases or Affiliates and, in particular, the locations specified inSection 7 Data Retention.

You have the right to access your personal information, how we use it, and who we disclose it to. You have the right to correct any of your personal information that is inaccurate.

South Korea

If you are in South Korea, the following additional information applies to you in addition to the Privacy Policy set out above.

Destruction of your personal information

If we determine that your personal information is no longer needed, we will destroy it under the supervision of our chief privacy officer and in accordance with applicable law and the Privacy Policy.

Personal information in the form of electronic files will be securely deleted using technical methods to prevent recovery and reproduction, and printouts will be destroyed by shredding or incineration.

Data subject rights

In addition to the information set out in Section 8 Your Rights and Choices in the Privacy Policy above, you have the right to request the suspension of processing: You may have the right to request the suspension of processing of your personal information that we have collected and processed. However, such a request may be denied under applicable laws or regulations. In many circumstances, we need to process your personal information in order to provide you with the services you require. If you do not provide the necessary personal information, or if you request the suspension of its processing for these purposes, we may be unable to continue providing you with the services you require.

Taiwan

We do not knowingly collect or solicit personal information from anyone under the age of 7 or knowingly allow such persons to register on Our Services. If you are under 7 years of age, please do not attempt to use or register for our Service or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using Our Services. In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using Our Services.

Thailand

By clicking “accept”, you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use Our 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 Our 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 with access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of 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

• lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us as set out in Section 12 Contact Us.

United States

(a) General

Why We Collect and Process Your Personal Information

In order to provide Our Services to you, we collect and process the following categories of personal information described in greater detail than in Section 1 What Data We Collect and Process, for one or multiple purposes described below, and for any other purposes for which we provide specific notice at the time the information is collected.

Categories of Personal Information	Purposes of Use
Contact Information and Identifiers/Account Registration Information, Service Account Information, Date of Birth (if any), Connected Social Media Account Information (Third Party), IP address & Device Data	Facilitate your use and access to, or to restrict your use or access to, Our Services
Contact Information and Identifiers/Account Registration Information, Service Account Information, Date of Birth (if any), Connected Social Media Account Information (Third Party), Personal Profile Information	Allow you to create accounts that enable you to manage your account and personal profile
Contact Information and Identifiers/Account Registration Information, Service Account Information, Date of Birth (if any), Payment Data	To facilitate our age verification process (if applicable)
Contact Information and Identifiers/Account Registration Information, Service Account Information, Game Data, User Service Information, IP address & Device Data, Device Related Data, Cookies Data, Data Related to Bugs, Errors, Crashes and Diagnosis, Security Related Data, Services Interaction and/or Usage Data, Information About Your Interaction With Others, Data Shared with Us by Third Parties	To facilitate your download of our games including any related troubleshooting
Contact Information and Identifiers/Account Registration Information, Service Account Information, Date of Birth, Connected Social Media Account Information (Third Party), Personal Profile Information, Game Data, Chat Data, Community Forum Information, User Generated Content, Malicious Content Information, User Service Information, Survey Information, Activity Participation Information, IP address & Device Data, Advertising Information, Payment Data, Pay Pal Account, Inferences	Provide you with the services you require and perform our contractual obligations towards you
Contact Information and Identifiers/Account Registration Information, Service Account Information, Date of Birth (if any), Connected Social Media Account Information (Third Party), Personal Profile Information, Game Data, Chat Data, Community Forum Information, User Generated Content, Malicious Content Information, User Service Information, Survey Information, Activity Participation Information, IP address & Device Data, Advertising Information, Payment Data, Inferences	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
Contact Information and Identifiers/Account Registration Information, Service Account Information, Connected Social Media Account Information (Third Party), Game Data, User Service Information, IP address & Device Data, Payment Data, Inferences, Device Related Data, Cookies Data, Data Related to Bugs, Errors, Crashes and Diagnosis, Security Related Data, Services Interaction and/or Usage Data, Information About Your Interaction with Others, Data Shared with Us by Third Parties	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
Game Data, Community Forum Information, User Generated Content, User Service Information, Survey Information, Activity Participation Information, Inferences	Develop new services or products and improve the user experience
Contact Information and Identifiers/Account Registration Information, Service Account Information, Connected Social Media Account Information (Third Party), Game Data, IP address & Device Data, Payment Data	Verify and confirm payment
Contact Information and Identifiers/Account Registration Information, Service Account Information, Game Data, IP address & Device Data, Advertising Information, Inferences	Deliver advertising that may be relevant to your interests and track the success of our advertising and marketing programs
Contact Information and Identifiers/Account Registration Information, Service Account Information, Connected Social Media Account Information (Third Party), Personal Profile Information, Game Data, Chat Data, Community Forum Information, User Generated Content, Malicious Content Information, User Service Information, IP address & Device Data	Communicate with users (including by sending text messages and/or push notifications) and take action against violations
Date of Birth (if any), Personal Profile Information, Game Data, Community Forum Information, User Generated Content, User Service Information, Survey Information, Activity Participation Information, IP address & Device Data, Inferences	Personalize your experience
Contact Information and Identifiers/Account Registration Information, Service Account Information, Date of Birth (if any), Connected Social Media Account Information (Third Party), Personal Profile Information, Game Data, Chat Data, User Service Information, Activity Participation Information, IP address & Device Data, Payment Data	Provide you with customer service support
Service Account Information, Personal Profile Information, Game Data, Chat Data, Community Forum Information, User Generated Content IP address & Device Data	Create contact with other users of Our Services
Contact Information and Identifiers/Account Registration Information, Connected Social Media Account Information (Third Party), Community Forum Information, User Generated Content, Activity Participation Information	Facilitate your participation in our user events
Contact Information and Identifiers/Account Registration Information, Service Account Information, Date of Birth (if any), Game Data, Community Forum Information, Activity Participation Information, IP address & Device Data, Advertising Information, Payment Data, Inferences	Keep you up to date with the latest product announcements, and provide other information pertaining to Our Services
Contact Information and Identifiers/Account Registration Information, Service Account Information, Game Data, IP address & Device Data, Inferences, Device Related Data, Cookies Data, Data Related to Bugs, Errors, Crashes and Diagnosis, Security Related Data, Services Interaction and/or Usage Data, Information About Your Interaction with Others, Data Shared with Us by Third Parties	Provide software verification, upgrades and administration, notify of special events
Service Account Information, Survey Information, Activity Participation Information, Inferences	Offer to participate in our surveys, events or activities
Contact Information and Identifiers/Account Registration Information, Service Account Information, Date of Birth (if any), Connected Social Media Account Information (Third Party), Personal Profile Information, Game Data, Chat Data, Community Forum Information, User Generated Content, Malicious Content Information, User Service Information, Survey Information, Activity Participation Information, IP address & Device Data, Advertising Information, Payment Data, Inferences	Fulfil our obligations under applicable laws and regulations, respond to requests of government authorities
Contact Information and Identifiers/Account Registration Information, Service Account Information, Date of Birth (if any), Connected Social Media Account Information (Third Party), Personal Profile Information, Game Data, Chat Data, Community Forum Information, User Generated Content, Malicious Content Information, User Service Information, Survey Information, Activity Participation Information, IP address & Device Data, Advertising Information, Payment Data, Pay Pal Account, Inferences	Establish, exercise, or defend legal claims
Service Account Information, Date of Birth (if any), Game Data, Community Forum Information, User Generated Content, Malicious Content Information, User Service Information, Survey Information, Activity Participation Information, IP address & Device Data, Advertising Information, Payment Data, Inferences	Analyze, profile, segment, merge and/or update all collected data (regardless of an aggregated or individualized manner) for the purposes of improving service quality and providing a better experience
Contact Information and Identifiers/Account Registration Information, Service Account Information, Date of Birth (if any), Connected Social Media Account Information (Third Party), Game Data, Community Forum Information, User Generated Content, Malicious Content Information, User Service Information, IP address & Device Data, Payment Data	Protect the integrity, information safety, and financial security of Our Services or users, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of Our Services
Contact Information and Identifiers/Account Registration Information, Service Account Information, Date of Birth (if any), Connected Social Media Account Information (Third Party), Personal Profile Information, Game Data, Chat Data, Community Forum Information, User Generated Content, Malicious Content Information, User Service Information, Survey Information, Activity Participation Information, IP address & Device Data, Advertising Information, Payment Data, Inferences	Conduct user research
Contact Information and Identifiers/Account Registration Information, Service Account Information, Connected Social Media Account Information (Third Party), Game Data, IP address & Device Data, Payment Data, Device Related Data, Cookies Data, Data Related to Bugs, Errors, Crashes and Diagnosis, Security Related Data, Services Interaction and/or Usage Data, Information About Your Interaction with Others, Data Shared with Us by Third Parties	Track your process across our websites and applications to verify that you are not a bot and to optimize Our Services

Data Retention

Where your data is required to be deleted in accordance with your request or where we are legally required to do so under applicable law or otherwise, we may retain certain personal information where permitted or required under law.

Appeals

If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us and specifying that you wish to appeal. Within 60 days of receiving your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision.

Right to Opt-out of Targeted Advertising and Data “Sales”

Some privacy laws define “sale” broadly to include some of the data disclosures described in Section 6 Information Sharing, in particular certain sharing with third-party providers for targeted advertising purposes. To opt-out from targeted advertising and any related data “sales,” you have several options. You can use browser or device-level controls as follows:

• Do Not Track: Your browser settings may automatically transmit a “Do Not Track” signal to online services you visit. However, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.

• Mobile Advertising ID Controls: iOS and Android operating systems provide options to limit tracking, reset the advertising IDs, or both.

• Email Web Beacon Controls: Most email clients have settings that allow you to prevent (a) the automatic downloading of images, including web beacons, and (b) the automatic connection to the web servers that host those images.

Your privacy choices apply only to the device or browser you use when you make them. If you use Our Services on a different device or browser, you’ll need to set your preferences again so they apply to that use as well.

(b) Additional Terms for California Residents

California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”) requires us to provide our users who reside in California with the additional notice below.

For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by CCPA.

Personal Information does not include information that is:

• Lawfully made available from government records
• Deidentified or aggregated; or
• Otherwise excluded from the scope of the CCPA.

We collect and disclose the categories of Personal Information as set out in Section (a) General, for the business purposes also set out in Section (a) General.

If you are a California resident, and the processing of Personal Information about you is subject to the CCPA, you have certain rights with respect to that information:

Notice at Collection.

At or before the time of collection, you have the right to receive notice of our practices, including the categories of Personal Information and sensitive Personal Information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Privacy Policy by referring to this and the above-referenced sections.

Right to Know

The right to request a copy of the Personal Information that we have collected about you in the prior 12 months. You also have the right to request additional information about our collection, use, disclosure, or sale of such Personal Information. Note that we have provided much of this information in this Privacy Policy.

Rights to Request Correction or Deletion.

You also have the right to request that we correct inaccurate Personal Information and that we delete Personal Information under certain circumstances, subject to a number of exceptions.

To make a request to correct or delete, please do so by emailing us using the contact information in Section 12 Contact Us of this Privacy Policy.

Right to Opt-Out / “Do Not Sell or Share My Personal Information”

You have a right to opt out from future “sales” or “sharing” of Personal Information as those terms are defined by the CCPA. Note that the CCPA defines “sell,” “share,” and “Personal Information” very broadly, and some of our data disclosures described in this Privacy Policy may be considered a “sale” or “sharing” under those definitions.

In particular, we allow advertising and analytics providers to collect identifiers (IP addresses, cookie IDs, and mobile IDs), activity data (Browse, clicks, app usage), and device data through our sites and apps when you use our online services, but do not “sell” or “share” any other types of Personal Information. If you do not wish for us or our partners to “sell” or “share” Personal Information relating to your visits to our sites for advertising purposes, you can make your request by emailing us using the contact information in Section 12 of this Privacy Policy.

Please note that we do not monetize Personal Information in the sense of disclosing your Personal Information in exchange for money. Please also note that, if you exercise your right to opt-out of the “sale” and “sharing” of your Personal Information, we may still disclose your Personal Information to third parties for purposes other than cross-contextual behavioral advertising, as described in our privacy disclosures. Further, using these choices will not opt you out of the use of previously “sold” or “shared” Personal Information or stop all interest-based advertising.

We do not knowingly sell the Personal Information of minors under 16 years of age.

Right to Limit Use and Disclosure of Sensitive Personal Information.

You have the right to limit our use and disclosure of sensitive Personal Information to purposes specified at Section 7027(m) of the CCPA Regulations. We do not collect sensitive Personal Information as the CCPA defines this term.

Right to Non-Discrimination.

You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine The Light

Under California’s Shine the Light law, once per year, customers who are residents of California may request (i) a list of the categories of Personal Information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. Please be aware that we do not disclose Personal Information to any third parties for their direct marketing purposes as defined by this law. California Customers may request further information about our compliance with this law by emailing the address provided in Section 12 Contact Us.

Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.

California Eraser Request

If you are a California resident under 18 years old who is registered with us, you can ask us to remove any content you have publicly posted by contacting us and specifying that you are making a “California Eraser Request”. We will make reasonable and good faith efforts to remove the post from prospective public view. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post, and archived copies of it may be stored by search engines and other parties that we do not control.

Communication and Verification

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof that you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

Further, to provide, correct, or delete specific pieces of Personal Information, we will need to verify your identity to the degree of certainty required by law. We will verify your request through common market practices, including by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.