2bytes Privacy Policy

※ Effective Date : July 31, 2023

Article 1 Policy Information

2bytes Corporation (hereinafter referred to as ""2bytes"" or ""Company"" or ""We"" or ""Us"") is an information technology company that designs, develops and services PC and mobile games. Through this Privacy Policy, the Company provides a clear explanation on how and why it collects, stores, and shares your personal information within the bounds of the law of the state where the Company conducts its business. The Company considers your personal information and the security of your personal information to be of great importance and will continue to place such importance on them in the future. In this Privacy Policy, ""Personal information"" means all information that can specify or specify the identity of a living individual.
This Privacy Policy applies to all online and offline services provided by 2bytes as well as websites, mobile applications, forums and all social media channels used to service 2bytes's games. This also applies to other services that the Company provides for the Company's marketing and advertising activities on all platforms. In this Privacy Policy, we refer to services, including the game, website, and marketing, advertising activities, and other services of the Company collectively as ""services"".
If you download the Company's PC program or mobile application, download or access the Company's game, or use the Company's website or other services, the Company will process your personal information for the provision of the service. If you have any concerns about providing your information to the Company or the Company using your information as described in this Privacy Policy, you should not use the game and other services of the Company.

Article 2 User Data Collection
2-1. The Company may collect personal information from you directly or from other third-party companies that have obtained your consent or other legal rights to share such personal information with the Company (including advertising platforms, affiliates, and data collection agencies). This may include information about your personal characteristics and interests, as well as the games and services you use, your gaming and service usage environment, personal information, and general location information. The Company will use your personal information as described in this Privacy Policy.
2-2. If you download or access the Company's games, or use other services provided by the Company, the Company collects and processes your personal information for the purpose of providing the service. The information collected and processed includes the following:
a. The following information is collected when you sign up as a member:
a-1. Wide-range location data (e.g. national or city-level data).
a-2. When using a mobile account: mobile phone number (account name), two-factor authentication number (PIN number)
a-3. When using an email account: email address (account name), password
a-4. When using a Steam account: Public profile (name), Steam ID, purchase history
＊When signing up using external platform authentication, no other personal information will be stored except for the information mentioned above.
b. The following information may be collected during the use of services.
b-1. Service usage records, access logs, IP information, records of improper use, PC MAC information, mobile device information (model name, mobile carrier information, OS information, language and country information, unique device identification number, advertising ID).
b-2. Notices on events and promotions: [Optional] mobile phone number, email address.
b-3. Prizes and item delivery: [Required] name, mobile phone number, phone number, address
b-4. Participation in events, surveys, and questionnaires: [Optional] name, mobile phone number, gender, date of birth, email address.
b-5. Inquiries: [Required] nickname, email address (for non-member inquiries). [Optional] ID, name, email address, mobile phone number, date of birth, gender, address, phone number, self-verification information, payment information (additional personal information may be collected depending on the inquiry type).
c. For the purpose of ensuring service stability, preventing improper use, protecting accounts and items, and restricting acts in violation of the law and the terms of use, information that is automatically generated during the process of using the service (IP, access logs, service usage records, records of improper use, download records, payment records, cookies), information that can identify devices (OS information, hardware information, MAC address, UUID, advertising identifier), and location information may be collected.
d. When using the Company's services with another company's account (such as Apple, Google, Facebook, etc.) as is the case for social logins, only the user's identification data and personal information agreed upon by the user for identification purposes will be provided to the relevant company and will be processed only within the scope of the agreed purpose.
e. If you register to receive news or notifications from us, we may collect your email address, areas of interest, and communication preferences. To stop receiving email messages, you can use the opt-out link included in the email.
f. When installing or purchasing items related to mobile apps that can be purchased through the App Store or Google Store, we do not have access to credit card or bank account data. However, as mentioned above, third-party payment processors may share non-financial information related to your purchases with us to fulfill your order. Personal data received from third parties may vary depending on the privacy settings of the relevant third-party application.

Article 3 Purpose of Data Collection
3-1. The Company collects and uses your personal information for the following purposes.
a. To provide the Company's games, activate your purchases within the games, and provide player support to you when necessary.
b. To optimize the Company's games for you and the devices you use, and to deliver in-game events, products, and promotions tailored to you.
c. For other purposes described in this Privacy Policy, including marketing and advertising purposes.
d. To operate, improve, and optimize the Company's games and other services.
e. To personalize the Company's services, to enhance the user experience and enjoyment of the Company's services by understanding users and their preferences, and to improve the user experience.
f. To provide access to specific areas, features, and characteristics of the Company's services.
g. To notify you of in-game updates, new products, and promotional items.
h. To send you relevant information including confirmation messages, technical notifications, updates, security alerts, support and operational messages.
i. To enable members to communicate with each other through the Company's social media accounts or within the game.
j. To respond to your comments and inquiries, and to provide customer support services.
k. To prevent potential acts that are prohibited or illegal and to protect the members of the Company.
l. To measure interest in the Company's services.
m. To perform internal quality controls.
n. To comply with the laws applicable to the Company, prevent fraud, comply with the Company's terms of service, and defend and exercise the Company's legal rights, including rights specified in the Company's terms of service, as necessary.
o. To contact you as part of the hiring process.
p. For cases other than those stated separately in our Privacy Policy or those requested by law.

Article 4 Marketing
4-1. The Company and its third-party affiliates utilize the personal information collected about you to send you marketing information related to the Company's PC and mobile applications and related services based on your interests. For example, the Company may post advertisements within its services or on third-party websites and applications.
4-2. The Company may utilize the information it possesses about you to promote its services in various ways. Methods may include the following:
a. Advertising within third-party websites or applications.
b. Customized promotions related to the Company's services within the game that you play.
c. In-game advertisements and special offers related to 2bytes services and its games.
4-3. The Company utilizes the information it possesses about you to ensure that you only see advertisements that may be of interest to you. To achieve this, the Company may possess the following information about you.
a. Advertising identifiers and other non-personal information collected from your device.
b. Information about the games you play and how you interact with the Company's games and services.
c. State and region
d. Other information that the Company can obtain from third-party marketing partners or other third parties who have legal rights to share such information with the Company or have obtained your consent.
4-4. When the Company markets its games through other companies in the media, the Company uses various third-party marketing partners to assist the Company, and the Company may share the information collected from you with these third parties.
a. The Company's marketing partners can assist the Company in exposing ads to you by combining the data they have collected about you elsewhere with this information. They collect this information when you use their services or website or when you use third-party services. The Company's partners use this information to predict ads that you may be interested in seeing. If they are confident that you will be interested in ads related to the Company's games or services, they will expose you to the Company's ads while you are using other websites or services.
b. If you do not want your personal information to be used for receiving interest-based ads, you can request the Company to opt-out by contacting customer support. Even if you opt-out of receiving interest-based or targeted ads, ads may continue to be displayed, and ads related to the Company's products may be displayed. Please note that these ads are not displayed based on your personal information.
c. If you accept this Privacy Policy and download or continue to play the Company's games, the Company's marketing partners may collect and use your personal information to improve their advertising, targeting, and measurement systems, as described in their own privacy policies, unless you decide not to receive interest-based advertising as described in this section.
d. This Privacy Policy applies to the collection and use of your personal information by the Company (the one who created the game or service you are using). However, it does not apply to the collection and use of your information by the Company's marketing affiliates. For more information on this, it is recommended that you review the Privacy Policy of the Company's affiliates.

Article 5. Matters Concerning the Installation, Operation, and Refusal of Automatic Personal Information Collection Devices
5-1. The Company operates "cookies" and similar technologies that continuously store and retrieve information about the user. Cookies are very small text files that are sent by the server operating the Company's website to the user's browser and stored on the user's computer hard drive. The Company uses cookies for the following purposes:
5-2. Purpose of using cookies, etc.
A. The Company analyzes the frequency of visits and time spent by members and non-members, as well as track their interests and preferences, and determine their visit history in order to provide personalized services. Web/mobile service visit records and activity logs of users may be provided to Incross Co., Ltd. to deliver personalized advertising based on estimated gender/age and interests derived from demographic characteristics.
5-3. How to refuse cookies
A. Users have the choice to allow or deny cookie installation. Therefore, users can choose to allow all cookies by configuring their web browser settings, require confirmation every time a cookie is being saved, or reject the storage of all cookies. However, if a member chooses to reject cookie storage, it may cause some difficulties in accessing certain services.
5-4. How to set cookies
A. Internet Explorer: [Tool] → [Internet Option] → [Personal Information] → [Advanced]
b. Chrome: [︙] → [Settings] → [Personal Information and Security] → [Cookie and other site data]
c. Microsoft Edge: Settings → Cookies and Site permissions → Cookie and Site Data

Article 6. Advertising Identifiers, Software Development Kits and Similar Technologies
6-1. To provide our games, websites, and interest-based ads, we use advertising identifiers, software development kits, and similar technologies. Through these technologies, we and our third-party advertising partners can perform the following:
a. Recognize you and your devices.
b. Offer interest-based ads.
c. Allow our service to interact with third-party social networks or platforms (if such interaction were allowed).
d. Provide you with more personalized services (e.g. providing our services in the correct language).
6-2. Advertising identifiers are non -permanent non -permanent identifiers such as Android advertising ID and/or Apple Advertisement ID. Similar technologies include tracking pixels in ads. Through this technology, the Company (including marketers and advertisers) can recognize your device when using a website and application.
6-3. How to select the interest -based ad from the device and Facebook
A. Opting out of interest-based advertising at the device level: You can choose to prevent your device's advertising identifier from being used for interest-based advertising by changing your device settings or resetting your device's advertising identifier. Settings vary by device, but you can usually find advertising identifier settings under "Privacy" or "Ads" in your device settings.
b. Opting out of Facebook ads: To update your ad preferences on Facebook, you need to log into your account on Facebook and update your settings.

Article 7. Member's Rights
7-1. You have certain rights regarding your personal information and how we handle it. You can exercise these rights by contacting us using any of the methods listed at the bottom of this document. Your rights include the following.
a. Access to personal information: You have the right to access your personal information used by 2bytes.
b. Modification or deletion of personal information: If your personal information is incorrect or incomplete, you have the right to request that 2bytes correct or complete it by inquiring customer support. Additionally, under certain conditions, you have the right to request the deletion of your personal information from 2bytes by sending an inquiry to customer support.
c. Account deactivation: Deactivating the account completely involves detaching the Facebook account from the mobile game and deleting the game from the mobile device. Once the account is completely deactivated, all progress made in the game and all unused virtual items will be lost and cannot be recovered by the Company.
d. Restriction of personal information processing: Under certain conditions, you have the right to request that 2bytes restrict the use of your personal information.
e. Refusal of personal information processing: Under certain conditions, you have the right to object to 2bytes's use of your personal information.
f. Portability of personal data: Under certain conditions, you have the right to receive your personal information in a structured, commonly used, and machine-readable format to transfer it to another company for their use as well.
g. Right to Opt-Out (US, California): California residents have the right to opt-out of the sale of their personal information. This right is defined in a way that may include transferring information to third parties for the purpose of personalizing advertisements for you. If you opt-out of the sale of your information, the Company will not sell your information to advertising partners, etc. However, you may still see ads in the game and some of our partners may still show you ads based on information they have about you.
7-2. There are other ways in which you can control the personal information collected by the Company related to you. For example, you can unlink your social network accounts such as Facebook from the Company's games or delete the Company's games from your device. Additionally, you can use your phone's settings to reset your mobile advertising identifier or limit ad tracking based on your preferences.
7-3. Occasionally, the Company may send push notifications to you through its mobile application about game updates, high scores, and other content that may interest you. You can always choose to opt-out of receiving these types of notifications by changing your mobile device settings.
7-4. If you want to send an inquiry about personal information, you can go to customer support through the link below.

Contact Customer Center

Article 8. Disclosure of Your Personal Information
8-1. As stated in this Privacy Policy, (in order to provide services through third-party service providers, comply with legal obligations, and protect the rights and property of the Company), the Company may share your information within the scope of the services described in this Privacy Policy.
A. Service provider
a-1. The Company may share your personal information with its service providers. The types of data processors that the Company entrusts include (i) companies that provide IT and related services, (ii) companies that provide information and services requested by you, (iii) companies that provide customer service activities, (iv) companies that provide analysis and search engines to assist in improving and optimizing the Company's services, and (v) companies that provide all support activities related to the Company's services. To comply with legal requirements and perform contracted services on behalf of the Company, 2bytes has executed contracts prohibiting service providers from utilizing or sharing personal information except when it is essential. This will also be enforced in the future.
b. Disclosure for the purpose of protecting the rights of the Company, you, and others (e.g. disclosure required by law or similar circumstances).
b-1. The Company may access, retain, and disclose your personal information and other account information in the following circumstances when it is deemed necessary or appropriate: (i) to comply with law enforcement or national security requests, as well as legal processes such as court orders or subpoenas, (ii) to respond to your requests, (iii) to protect the rights, property, or safety of you, the Company, or others, (iv) to fulfill the policies or contracts of TwoBytes, (v) to collect amounts owed to TwoBytes, (vi) to investigate and prosecute physical or financial damages or suspected or actual illegal activities, or when disclosure of information is deemed necessary or appropriate, and (vii) in other cases where the Company deems it necessary or desirable to disclose such information in good faith. Additionally, server logs may occasionally be checked for security purposes (e.g. to detect unauthorized activities on the Company's service). In such cases, server log data, including IP addresses, may be shared with law enforcement agencies to identify users involved in unauthorized activities investigations.
c. Asset sales and change of management control
C-1. In cases where assets of 2bytes are sold or there is corporate restructuring, or when the ownership structure of 2bytes shares is changed or there is a change in management due to preparing for such cases, any third party who acquires or transfers the assets of 2bytes has the right to continue using the personal and other information provided by you to the Company in accordance with this Privacy Policy.

Article 9. Overseas Transfer
All personal information collected and stored by 2bytes is not limited to, but may be stored anywhere in the world, including servers in South Korea, the United States, the European Union, the cloud, the Company's servers, and the Company's service provider servers. If 2bytes transfers your personal information overseas, 2bytes will handle your personal information in a safe, legal, and manner described in this document through proper procedures. Personal information protection laws that apply to the location where your personal information is transferred, stored, used, or processed may differ from the personal information protection laws that apply to the location where you reside because the laws vary by jurisdiction.
By providing your personal information to 2bytes, you agree to have your personal information stored in the locations specified above. If you use 2bytes' services in the European Union or other regions where laws on the collection and use of information apply, please note that you are consenting to the transfer of your personal information to South Korea and the United States and that your personal information may be processed worldwide.
By visiting the 2bytes website, using 2bytes' services, or providing information to 2bytes, you agree that South Korean law applies to all disputes related to personal information or any provisions contained in this Privacy Policy and that decisions regarding any disputes related to 2bytes or the website will comply with the terms of service.

Article 10. Security
The personal information you provide to 2bytes is stored on servers located in secure facilities and is protected by protocols and procedures designed to ensure industry-standard security measures such as firewalls and encryption. However, there is no guarantee that any server, computer, communication network, or system, or data transmission over the internet is 100% secure. Therefore, while 2bytes will make every effort to protect your personal information, it cannot guarantee or warrant the security of the personal information you transmit to 2bytes or through the Company's services over the internet. By using the Company's services or providing personal information to the Company, you agree that the Company may electronically contact you regarding operational issues related to the security of your personal information and your use of the Company's services. In the event of any security system issues, the Company may notify you electronically by posting notices on its services or sending you an email.

Article 11. Data Preservation
We have your data for the period you need to provide your account for your account or to provide you with your service. If you ask the Company to remove personal information, the Company preserves your information according to the need for legitimate business interests, such as complying with legal obligations, resolving disputes, and implementing the Company' rules. Please note that it can.

Article 12. Legal Basis (for users in the European Economic Area)
12-1. If you are an individual residing in the European Economic Area (EEA), we will only collect and process your personal data if we have a legal basis for doing so under the applicable EU laws. The legal basis that we rely on includes the following:
a. Necessity for contractual obligation: This includes information that we use to provide services that you have requested and agreed to provide, such as games, customer service, chat functionality, and third-party social network connections.
b. Legal obligation: This includes information that we use to comply with legal obligations, such as maintaining records related to taxes or responding to valid legal requests for specific data.
c. Legitimate interest: This refers to information that we use for purposes that can reasonably be expected within the context of your use of our services, such as marketing, advertising, analysis, research, optimization of our games and other services, provided that it is not harmful to your personal information.
d. Consent: This is used as a legal basis in the context of consenting to the collection of data, including device information, ad identifiers, IP addresses, country, and region stored on your device by the Company and its advertising partners. By agreeing to install the Company's game, you consent to this collection. You can withdraw your consent by deleting the Company's game.
12-2. In this Privacy Policy, we have explained how the Company handles certain types of processing and how you can withdraw your consent for any processing that is based on your consent, in accordance with the methods described in this Privacy Policy. However, if you choose to play the Company's games, the Company will collect and process some personal information about you as described separately in this Privacy Policy. If you do not want the Company to collect any personal information about you, you should not play the Company's games or use the Company's services.

Article 13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time, and we will post the updated policy on this page. All new policies will be effective from the date we publish them.

Article 14. Inquiries
If you wish to contact us or exercise your rights as stated in this Privacy Policy, please contact us via the help center email or through the 1:1 inquiry function within the game.

Article 15. Transfer of personal information outside the EU/European Economic Area
We share your personal data with our affiliates and partners within and outside the EU/EEA. If data transfer outside the EU/EEA is not covered by an adequacy decision of the EU Commission, we rely on the legitimate protection measures mentioned in GDPR article 46. These include reinforced EU Commission-approved standard contractual clauses that contain additional security measures such as additional encryption or pseudonymization and additional individual risk assessments to enable international transfers with PLR affiliates and partners outside the EU/EEA. The full text of the EU Commission-approved standard contractual clauses can be found through this link. Please contact the help center for further information on our protection measures and additional security measures for third-country data transfers.

We share personal data with external suppliers, service providers, or vendors who participate in performing services or functions on our behalf in compliance with our instructions. If these suppliers are within the EU, we ensure that they have a contractual obligation to comply with EU data protection rules. Moreover, we guarantee that these organizations process personal data only to provide the agreed-upon services and to protect the integrity and confidentiality of your personal data delegated to them in accordance with our instructions.

We may also disclose personal data to consultants, law enforcement authorities, and other public authorities (e.g., tax and social security institutions), police, prosecutors, courts, and tribunals. All these recipients have a responsibility to comply with EU data protection rules.

Some of the suppliers we work with are located outside the European Economic Area. If the EU Commission does not recognize that adequate protection is provided for personal data, we rely on the legitimate protection measures described above.

Please contact us at the email address provided in the Data Controller and Contact section above to request a copy of these contracts.