FLYWAY GAMES

Ascend to ZERO | 개인정보 처리방침

Overview
What Information Do We Collect
How We Use Your Information
How We Share Your Information
Cookies and Related Technologies
International transfer of personal information
Retaining and Deleting Personal Information
Our Policy Concerning Minors
Links and Third-Party services
Security of Your Information
Your Privacy Rights
Amendments
Contact Us
Appendix. SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC
Overview
Flyway Games, Inc. ("Company", “we”, “our”, or “us”) processes your (“you”, or “user(s)”) personal information in the course of providing all services ("Service(s)"), including but not limited to websites and applications. We comply with applicable laws and regulations in the countries and regions where we conducts business, and establish and disclose the following Privacy Policy ("Policy") in order to protect users' personal information promptly and smoothly deal with the complaints related thereto.

Scope of the Privacy Policy
We provide and operate various Services, and each Service may have a separate privacy policy.
This Policy applies to "Ascend to ZERO” ("Service(s)”),and explains your rights regarding the processing of personal information, as well as how to communicate with us. This does not apply to personal information processed on other companies’ websites or applications linked to the Service.

What Information Do We Collect
We will collect and use the following categories that may directly or indirectly provide or operate our Services.
We may use non-personal information, including data generated during the user's Service usage history (e.g. service information, account activation status, access record, IP address, anti-cheat record, campaign participation history, payout details, language, country, etc.), for purposes such as analyzing the Service usage environment, improving the Service, and to improve the quality of the Service. And when you participate in social features (such as text or voice chatting), the information that you disclose is public information. We may store and access it, and it may be processed or used by other users without notice.

Personal information that you provide directly

Name, nickname, email address, social platform information (such as platform name, platform account name, etc.), date of birth, to provide or operate Services
Email address and inquiry details when using customer support Services
Email address, nickname, gender, age group, postal address, phone number, date of birth, country when participating in promotions, such as events or survey (if applicable) information required for giveaway and/or tax (e.g. name, address, phone number, (if applicable) tax id, etc.)

Personal information we collect automatically
We collect your personal information automatically as below.

User identifier
Consent history (i.e. legal document such as Terms of Service, and Privacy Policy, etc.) (such as user identifier, type and version of legal document, consent date and time)
Payment Information (such as purchase date, items, etc.)
Device information (such as OS version, browser type, language setting, MAC address, etc.)
Cookies (more details in “5. Cookies and Related Technologies”)

Personal information we collect from other sources
In accordance with the Services Terms of Service, the use of KRAFTON ID and social platform accounts are required to use this Service. We collect your personal information as below.

When you log in with KRAFTON ID to use the Service, we will use your account information (such as email address, date of birth, (if applicable) external account linking information, and service usage history, nationality, etc.) collected in accordance with the KRAFTON ID Terms of Service and Privacy Policy [https://accounts.krafton.com/privacy-policy].
When you enter a creator code in the KRAFTON Creator Network(“Network”) pop-up within the game, we will use your account information (such as platform ID, creator code, etc.) collected in accordance with the Network Terms of Service and Privacy Policy [https://creators.krafton.com/en-US/clause/privacy_policy]
If you link your social platform account while signing up and using for Services, we will use your social platform information (such as platform ID, platform name, profile image, etc.) that is publicly available on the Internet.

How We Use Your Information
We process your personal information for the following purposes.

To identify users and confirm their intent to use the Service
To analyze the Service usage environment and improve usage experience
To improve the quality of the Service and develop new services
To manage inquiries and requests
To support Service failures and stability
To prevent illegal or unauthorized use
To secure and protect your account
To restrict violations of laws and our Terms of Service
To notify promotions, such as campaigns, play tests, pre-registrations, updates, and event participation for all services provided by us
To provide and manage promotions(i.e. to contact and identify the winner, giveaway, or tax)
To analyze statistics (such as leaderboard, etc.) on Service usage patterns and trends
To participate in our official Partnership Programs

We will notify you of relevant matters and obtain your consent in order to legally process your personal information, but if permitted by applicable laws and regulations in the country or region where we operate its business, your personal information will be processed based on one of the following legal grounds.

When necessary to perform a contract with a user or take measures at the user's request in the course of the process of concluding a contract
When there are special regulations in the law or it is inevitable to comply with legal obligations
When it is deemed necessary for the significant interests of the user or a third party
When it is necessary to investigate and take measures to prevent fraudulent registration and use, security, privacy, and restrict violations of laws and our Terms of Service
When personal information processing is necessary to pursue legitimate interests of us or a third party within the scope that does not infringe on your privacy rights, interests, and freedom
When it is necessary to achieve the legitimate interests of us manifestly superior to the rights of the user. In such cases, processing shall be allowed only to the extent the processing is substantially related to our legitimate interests and does not go beyond a reasonable scope.

How We Share Your Information
We use personal information within the scope notified in "3. How We Use Your Information". In principle, we do not use or share any personal information beyond the scope without your prior consent. However, exceptions are made in the following cases.

When there is an obligation to share personal information in accordance with relevant laws and regulations

We may provide personal information in accordance with lawful procedures, such as when an administrative agency or investigative agency requests the provision of personal information in accordance with relevant laws and regulations, in the form of a warrant or a written document stamped with the seal of the head of the agency.

When outsourcing certain tasks to third parties

We may provide and operate tasks such as cloud computing services, customer support services to third parties for service operation, etc. We have stipulated matters for the safe management of personal information for the relevant trustee, and some of the outsourcing tasks are processed overseas.

Other

We may share your personal information where such disclosure is essential to comply with a legal obligation or a lawful data access request, pursuant to a merger, acquisition, reorganization, bankruptcy, or other similar event, with our subsidiary companies (LIST: https://krafton.com/en/studios/) for the purposes described in this Policy, or where you have otherwise provided your consent or at your request.

Joint use with an affiliated company
We may jointly use your personal information as below.

Recipient for joint use(Contact Info): KRAFTON Inc.(privacy@krafton.com)
Purpose: To provide KRAFTON ID Membership Service
Items joint used: All items listed in “2. What Information Do We Collect”
Retention and Usage Period: Until membership withdrawal, personal information deletion request
Method of Joint Use: Transmitted via a network when you register
Country of Provision (Joint Use): United States of America
Recipient for joint use(Contact Info): Krafton Americas Inc. (ka_privacy@krafton.com)
Purpose: Operation of the KRAFTON Creator Network (hereinafter "Network") service
Items joint used: All items listed in “2. What Information Do We Collect”
Retention and Usage Period: Until membership withdrawal, personal information deletion request, or until termination of the affiliated company's service
Method of Joint Use: Transmission through the Network upon entering a creator code in the in-game pop-up
Country of Provision: United States of America

Cookies and Related Technologies
We may automatically collect and use your personal information to analyze the Service usage environment and improve usage experience. We strive to provide a safe and fair gaming environment for all players. When you use our Services, we or third parties may use cookies and similar technologies, or collect data about your machine or device, for fraud prevention, security and authentication purposes.
International Transfer of Personal Information
We provide and operate the Services globally so we may transfer your data directly to other regions (i.e. United States, and Korea) outside your country of residence. When your personal information is transferred, stored, or processed overseas, we take reasonable measures to protect the privacy of your personal information, including, where appropriate, entering into confidentiality and standard contractual provisions with suppliers. The transfer of personal information overseas is essential for the operation and provision of Services. If refused, the Services cannot be provided.
Retaining and Deleting Personal Information
In principle, the personal information is destroyed when the purpose of collecting and using personal information is achieved. Examples of achieving the purpose of collecting and using personal information are as follows:

When the user requests withdrawal of membership or deletion of their personal information
When we terminate the provision of services
When the processing of the inquiries or complaints is completed
When the necessary procedures for providing promotions (such as events prize issuance, tax payment processing, etc.) are completed
When personal information is stored in physical form we will shred or incinerate the forms, or it is stored electronically we will delete using technical measures in a way that the information cannot be copied. However, we may retain your personal information even after you withdraw your account or we have ceased providing Services to you, if it is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Policy or other agreements we may have with you.

Our Policy Concerning Minors
We do not intend to target, nor knowingly collect information of individuals under the age of majority in your jurisdiction. Certain games may make limited exceptions with parental consent. If you are a parent or guardian and you believe your child has provided us with information, you can contact us and request your child’s information to be deleted from our system. Some Services that provided to underage users, we will obtain parent or guardian’s consent.
Links and Third-Party services
If you click on a link to a third-party website, including but not limited to advertisements, you will leave our website and go to the website you selected. Since we cannot control the activities of third parties, we cannot guarantee that they will adhere to the same privacy and security practices as we do. If you visit a third-party website linked to the Service, please check their Privacy Policies of the site before providing personal information. If you visit a third-party website linked to the Service, please check their Privacy Policies of the site before providing personal information.
Security of Your Information
We establish and apply the following optimal management, technical, and physical protection measures to prevent the loss, theft, leakage, forgery, alteration or damage of personal information.

Managerial Protection Measures

Establishment and implementation of internal management plans, regular employee training, supervision of security compliance of contracted companies, etc.

Technical Protection Measures

Management of access to personal information processing systems, installation and operation of access control systems, encryption of personal information, installation and operation of security programs, etc.

Physical Protection Measures

Access control of server room, data storage rooms, etc.

Implementation of and compliance with the Policy

We check the implementation of the Policy and the compliance of the controller, and if any problem is found, we immediately correct and rectify.
However, we are not responsible for any problems caused by the leakage of personal information, such as passwords due to your own negligence or problems on the Internet.

Your Privacy Rights
You may exercise the following rights at any point in time in connection with your personal information. To exercise such rights, please email us at az_contact@flywaygames.com. to request your rights. Please note that at least your email address will be required to submit a request, and additional information may be required so we can verify you. If you exercise your rights via email, you must specify the right(s) you wish to exercise. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. However, we may decline to process requests which are not otherwise required by applicable law.

Right to Know & Right to Access
You have the right to request the following information from us up to two times within a 12-month period, you can request access to your personal information by email.
a. the categories of personal information that we have collected from you over the past 12 months or since launching this Services, and the specific pieces of personal information we have collected from you;
b. the categories of sources from which personal information was collected;
c. the business or commercial purposes for which personal information is collected;
d. the categories of personal information that we have disclosed for a business purpose or sold during the past 12 months or since launching this Services, and
e. (if applicable)the categories of third parties to whom the information was disclosed or sold.
Right to Delete
You have the right to request that the personal information collected from you be deleted. However, we collect minimum personal information from you to provide you a Service. If you ask us to delete required items, you may no longer be able to access or use our Services. To submit your request, please email to us az_contact@flywaygames.com. Some personal information may be exempt from such requests under law. We may still retain your personal information to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Policy or other agreements we may have with you.
Right to Correct
You have the right to correct your personal information. You can request us by email az_contact@flywaygames.com.
Right to Non-Discrimination
You have the right not to be discriminated against for exercising these privacy rights. We will not deny, or offer you different items or services when you request your privacy rights.

Amendments
We always post the latest privacy policy through "Privacy Policy" at the bottom of the website. We can change the Policy, and if there is a significant change we will notify you in a way that is easy to understand. If the user does not agree to the changes and does not wish to use the Services anymore, you may withdraw your account. If you continue to use the Services after the changes are notified or posted on the Services, it will be considered as consent to the changed policy. In addition, we will separately request your consent if required by relevant laws.
Contact Us
If you have any questions about this policy or our processing of your personal information, please contact us at your convenience. We endeavor to fully answer your request in good faith.

Name of Chief Privacy Officer: Suyoung Kim
Affiliation: Flyway Games
Email: az_contact@flywaygames.com
Address: 327, Gangnam-daero, Seocho-gu, Seoul, Republic of Korea

Appendix. SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC
This portion of our Policy applies to residents of the jurisdictions indicated below. In the event of a conflict between the Policy and this section, this section supersedes and controls.
Additionally, this section is provided in English for the convenience of our global users. If there is a version available on the website in your native language, we recommend reviewing the document in your native language for a better understanding of the specific details for your region.

EEA and UK
If you are located in the European Economic Area (EEA) or the UK, you may lodge a complaint with an applicable data protection authority for your country or region where an alleged infringement of applicable data protection law occurs. You may also submit a request to exercise your rights with our representative. This representative is only for EEA or the UK residents. If a user residing in another country submits a request, the response time may vary depending on the data protection laws of that country.
Our representative in the EU is VeraSafe Netherlands BV, located at Keizersgracht 555, 1017 DR Amsterdam, Netherlands. To contact, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.
Our representative in the UK is VeraSafe United Kingdom Ltd., located at 37 Albert Embankment, London SE1 7TL, United Kingdom. To contact, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.
If we transfer your data outside of the EEA to a country that is not recognized by the European Commission as ensuring an adequate level of data protection, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the most recent standard contractual clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for personal data). You may ask for a copy of such appropriate measures by contacting us as set out in this Policy. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
Japan
If you are a resident in Japan, for any questions or issues in relation to the collection and handling of your personal information, you may reach out to our Chief Privacy Officer by sending an email to Chief Privacy Officer. We will respond to your concerns and queries at the earliest and in compliance with Japanese Act on the Protection of Personal Information, and Japanese Telecommunications Business Act, etc.

Joint Use of Your Personal Data
We may use your personal data jointly with our affiliates as follows.
a. Personal data used jointly
All of your personal data listed in “2. What Information Do We Collect”.

b. Scope of joint users & Intention of the joint use
We can use your information jointly where such disclosure is essential to comply with a legal obligation or a lawful data access request, pursuant to a merger , acquisition, reorganization, bankruptcy, or other similar event, with our subsidiary and affiliated companies (LIST: https://krafton.com/en/studios/) for the purposes described in this Policy, or where you have otherwise provided your consent or at your request.

c. Party responsible for management of the personal data
We have designated the following persons as the Chief Privacy Officer to remain responsible for responding to user inquiries regarding personal information and resolving any related complaints.

Name of Chief Privacy Officer: Suyoung Kim
Affiliation: Flyway Games
Email: az_contact@flywaygames.com
Address: 327, Gangnam-daero, Seocho-gu, Seoul, Republic of Korea

International Data Transfer
If we transfer your data outside of Japan to a country that is not recognized by the Personal Information Protection Commission as establishing a personal information protection system recognized to have equivalent standards the same in Japan, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the reasonable standard measures following the requirements of Section 1 of Chapter 4 in Japanese APPI. You may ask for a copy of such appropriate measures by contacting the Chief Privacy Officer. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
Your Privacy Rights
You have a right to request disclosure of your personal data retained by us (“Retained Personal Data”) and purpose of use thereof, disclosure of records of third parties transfer, correction, addition, deletion and discontinuance of the use and third parties transfer of the Retained Personal Data. To make a request concerning your rights above, please contact us by sending an email to Chief Privacy Officer(az_contact@flywaygames.com). In special cases (i.e. request your rights through mail, etc.), we may demand a fee when you request your rights.

Korea

Additional Explanation Regarding the Collection, Use, and Provision of Personal Information

Each item listed in Section 2, "Personal Information to Be Collected," of this policy is processed based on Article 15(1)(1) (consent of the data subject) or (4) (performance of a contract) of the Personal Information Protection Act.
Item 3 under "4. Sharing and Entrusting of Personal Information Processing" is provided to affiliated companies without your consent in accordance with Article 17(4) of the Personal Information Protection Act. Cross-border transfers may occur during this process in accordance with Article 28-8(1)(1)(a) of the Personal Information Protection Act (entrustment and storage of personal information for contract performance).

Procedures and Methods for the Destruction of Personal Information
In principle, users' personal information is handled in accordance with "7. The Retention Period and Destruction of Personal Information." It is, however, stored and managed only for the reasons specified below, and it will be destroyed without delay after the specified periods.

In the event of a request to terminate an account or delete personal information, any personal information collected for the purposes of providing support, protecting user accounts, resolving complaints and disputes, and operating membership services will be retained for up to 30 days from the date of the request and then destroyed.
Records of dishonest use during service will be retained for five years from the date of occurrence and then destroyed. If your service is permanently suspended due to dishonest acts in accordance with the Terms of Service and Operation Policy, however, records of such use will be stored separately and permanently.
The retention period for personal information collected for event hosting varies depending on the type of event and other factors. It follows the retention period specified on each event page. The Company generally retains such information for six months after the event ends (after the promotion period ends, prize distribution is complete, and tax and public charge processing is complete, if applicable) before destroying it.

Additionally, if an investigation or inquiry is underway due to a violation of relevant laws and regulations, we will retain your personal information until the investigation or inquiry is concluded. Furthermore, in accordance with Article 15(1)(2) of the Personal Information Protection Act (compliance with legal obligations) and relevant laws and regulations, if it is necessary to retain your information after the collection and use purposes have been fulfilled, the Company will retain your information for a specific period stipulated by relevant laws and regulations, as outlined below. Please refer to the "Legal Basis (Name of Law)" section for details regarding the relevant laws and regulations.

Category: Computer Communications, Internet Log Records, Connection Location Tracking Data
Personal Information Items: Date and Time of Access, IP Address
Legal Basis (Name of Law): Protection of Communications Secrets Act (Article 15-2)
Retention Period: Three months
Category: Records of Consumer Complaints or Dispute Settlement
Personal Information Items: All information collected for customer support services, either directly or automatically
Legal Basis (Name of Law): The Consumer Protection in Electronic Commerce, etc. (Article 6)
Retention Period: Three years
Category: Records Related to Contracts or Canceled Payments
Personal Information Items: User ID, Date and Time of Consent, IP Address - Legal Basis (Name of Law): The Consumer Protection in Electronic Commerce, etc. (Article 6)
Retention Period: Five years
Category: Records Related to Payment and Supply of Goods, etc.
Personal Information Items: (If applicable) Purchase History (Date and Time of Purchase, Item Name, Order Number, and Amount), and In-game Currency Usage History
Legal Basis (Name of Law): The Consumer Protection in Electronic Commerce, etc. (Article 6)
Retention Period: Five years
Category: Records Regarding Processing as Prescribed by Tax Laws
Personal Information Items: (If necessary) Information required for prize distribution
Legal Basis (Name of Law): Framework Act on National Taxes (Article 85-3), Corporate Tax Act (Article 116), and Income Tax Act (Article 160-2)
Retention Period: Five years

Entrustment of Personal Information Processing
The Company entrusts the processing of personal information to external specialized vendors as described below to ensure the smooth provision of services and has established regulations for these vendors regarding the secure management of personal information. Some of these entrusted tasks involve the transfer of relevant personal information overseas for processing. If there are any changes to the details of the entrusted personal information processing, we will notify you in advance. You may refuse the international transfer of your personal information by contacting Chief Privacy Officer and Personal Information Controller by email (az_contact@flywaygames.com). If you refuse the international transfer of your personal information,  the Company shall exclude your personal information from the overseas transfer target. However, in this case, the use of services that necessarily involve overseas transfer of personal information among the Company's services may be restricted. 
a.Details of Entrusted Processing

Legal Basis: Article 28-8, Paragraph 1, Item 3, Subitem (a) of the Personal Information Protection Act (Entrustment and Storage of Personal Information for Contract Performance)
Category (Details of Entrusted Work): Cloud server operation and management
Recipient (Contact Information): Amazon Web Services (https://aws.amazon.com/compliance/contact)
Personal Information Items: All personal information items specified in "2. Personal Information to Be Collected" of this Privacy Policy
Country to Which Information Is Transferred: The United States
Transfer Date and Method: Transmitted through the network at time of the service use
Period of Use of Personal Information: Until the user withdraws membership, requests deletion of personal information, or the entrustment contract is terminated
Legal Basis: Article 28-8, Paragraph 1, Item 3, Subitem (a) of the Personal Information Protection Act (Entrustment and Storage of Personal Information for Contract Performance)
Category (Details of Entrusted Work): Provision of a platform for user communication and promotion management
Recipient (Contact Information): FirstLook (Support@pragma.gg)
Personal Information Items: Email address, survey responses (including gender), and (if linked to an external account) platform account information
Country to Which Information Is Transferred: The United States
Transfer Date and Method: Transmitted through the network upon participation in a play test through KRAFTON ID
Period of Use of Personal Information: Until the user withdraws membership or the entrustment contract is terminated

b. Management and Regulatory Matters Regarding the Entrustment of Personal Information Processing

Purpose and scope of the entrusted work
Matters regarding the prohibition of personal information processing other than the purpose of performing the entrusted work
Matters regarding technical and administrative security measures to ensure safety such as restricting access to personal information
Matters regarding restrictions on re-entrustment
Matters regarding the Company's supervisory obligations, such as inspecting the management status of personal information held in connection with the entrusted work
Matters regarding liability, such as compensation for damages resulting from a breach of the entrusted company's obligation to comply with the above provisions, etc.

Rights of Data Subjects and Legal Representatives, and How to Exercise Them

In accordance with relevant laws and regulations, data subjects have the right to access, correct, delete, suspend the processing of, withdraw consent for, or object to automated decisions regarding their personal information, or request an explanation (hereinafter referred to as "access, etc."). If you have any questions about your personal information, please contact Personal Information Controller by email (az_contact@flywaygames.com). The Company will verify your identity and respond faithfully to your requests in accordance with personal information protection laws and regulations. Each of these rights may be exercised through the data subject's legal representative. In such cases, the legal representative shall have all the rights of the data subject.
The Company may provide KRAFTON ID services to children and supports the protection of children's personal information and the proper use of the service as follows. (A KRAFTON ID for the legal representative is required.)
(Legal Representative Consent Procedure: On the sign-up screen for creating a child's KRAFTON ID account, the legal representative must verify their identity through mobile phone or i-PIN. The legal representative will then review the details regarding the processing of the child's personal information and indicate their consent. If they consent, the Company will send a verification code to their KRAFTON ID (email address) to confirm consent for the child's account creation. Once the legal representative enters this verification code on the sign-up screen, the consent process is complete. During this process, the legal representative's authentication information \ [identity verification information (CI, Connecting Information), email verification results, and consent history regarding the processing of the child's personal information] is collected and generated.)
(Provision of the Guardian Settings System: The "Guardian Settings System" menu is created in the legal representative's KRAFTON ID.)
If the legal representative of a data subject requests access to personal information, the Company may require additional supporting documentation to verify the legitimacy of the representative's authority, such as the submission of a power of attorney in accordance with Form No. 11 of the "Notice on Personal Information Processing Methods."
The Company will ensure that the data subject and their legal representative can access the relevant personal information within ten days of their request. If there is a legitimate reason preventing access within that period, however, the Company may notify the data subject, extend the deadline, and provide access to the personal information without delay once the reason ceases to exist.
In response to requests for correction or deletion from data subjects, etc., the Company will take measures such as correcting or deleting the relevant personal information within ten days and notifying the data subject, etc., of the results unless procedures required by other laws and regulations apply. If deletion is not possible, such as when the personal information is explicitly designated as subject to collection under other laws and regulations, the company will notify the data subject, etc.
Requests by data subjects for access to personal information or suspension of processing may be restricted pursuant to Article 35(4) and Article 37(2) of the Personal Information Protection Act. Furthermore, if other laws or regulations explicitly designate such personal information as subject to collection, you may not request its deletion.
If we have obtained your consent regarding automated decision-making or have notified you in advance through a contract or other means, or if there are clear legal provisions, you cannot refuse automated decisions; only requests for explanation and review are permitted. Furthermore, requests to refuse automated decisions or to request an explanation may be rejected if there are justifiable grounds, such as a risk of unjustly infringing upon the life, body, property, or other interests of others.

Contact Information of the Chief Privacy Officer
The Company is responsible for the handling of personal information and has designated the Chief Privacy Officer (CPO) in charge as follows for handling complaints from data subjects related to personal information processing and remedies for damage.
a. Chief Privacy Officer (CPO)

Name: Kim Soo-young
Name of the Department: Flyway Games
Contact Information: az_contact@flywaygames.com
b. The following organizations are separate from the Company, and if you are not satisfied with the Company's own personal information complaint handling and damage relief results, or if you need more detailed help, please contact them.
Personal Information Breach Report Center (privacy.kisa.or.kr / [Toll-free] 118)
Personal Information Dispute Mediation Committee (www.kopico.go.kr / [Toll-free] 1833-6972)
Supreme Prosecutors' Office (www.spo.go.kr / [Toll-free] 1301)
National Police Agency (ecrm.cyber.go.kr / [Toll-free] 182)

c. Previous versions of this Privacy Policy may be viewed in the “Privacy Policy Revision History (LINK).”

United States

Privacy Rights for United States Users
Several U.S. states provide their residents with rights to:
a. Confirm whether we process their personal information;
b. Access and delete certain personal information;
c. Take their data from one location to another (data portability);
d. Opt-out of personal data processing for targeted advertising and sales;
e. Correct inaccuracies in their personal information, taking into account the information’s nature and processing purpose; and
f. Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise any of these rights submit a request form to our email(az_contact@flywaygames.com) . To appeal a decision regarding a consumer rights request, follow the instructions in the written notice we will provide to you.
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out right may submit a request to this designated address: (e-mail: az_contact@flywaygames.com) However, please know we do not currently sell data triggering that statute’s opt-out requirements.
California
If you are a California resident, you may have additional rights as detailed below.
Within the preceding 12 months, we have collected or disclosed the following categories of personal information about you
a. Identifiers, such as name, nickname, social platform information (platform name, platform account), language settings, etc.

How collected: When you access or use our Services, we collect this directly or indirectly from you.
How disclosed: With affiliates, subsidiaries, and service providers (e.g., cloud storage service provider)
b. Characteristics of protected classifications such as language settings, etc.
How collected: When you access or use our Services, we collect this directly or automatically from you.
How disclosed: With our affiliates, subsidiaries, and service providers (e.g., cloud storage service provider)
c. Internet or other network activity, such as browsing behavior while using our Services (e.g., browser type, OS version, etc.), identifiers such as IP address.
How collected: When you access or use our Services, we collect this automatically.
How disclosed: With our affiliates, subsidiaries, and service providers (e.g., cloud storage service provider)
d. Geolocation information obtained by IP address.
How collected: When you access or use our Services, we collect this automatically.
How disclosed: With our affiliates, subsidiaries, and service providers (e.g. cloud storage service provider).
e. Commercial information, such as payout details, etc.
How collected: When you purchase items in Services, we collect this automatically.
How disclosed: With our affiliates, subsidiaries, and service providers (e.g., cloud storage service provider)
We determine the retention duration for each of the categories of personal information listed above based on our business or commercial purposes for obtaining the information, our legal or regulatory requirements applicable to such information, and in relation to litigation or to protect our rights.
Your California Privacy Rights
You may exercise the following rights some rights are described in “11. Your Privacy Rights” at any point in time in connection with your personal information. To exercise such rights, please email us at az_contact@flywaygames.com to request your rights.
Please note that at least your email address will be required to submit a request, and additional information may be required so we can verify you. If you exercise your rights via email, you must specify the right(s) you wish to exercise.
We will verify your identity and respond to your request within 45 calendar days. If necessary, we may take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, in which case we will notify you to explain the reason for the delay.

Right to opt-out of Selling and Sharing
You have the right to opt-out of the selling and sharing of your personal information as defined by California law by requesting that your personal information not be sold or shared in any form. With respect to targeted advertising, you can control the sharing of your personal information for targeted advertising purposes through our website by opting out from advertising cookies through the cookie banner.
HOWEVER, WE HAVE NOT “SOLD” PERSONAL INFORMATION TO THIRD PARTIES AS THAT TERM IS DEFINED BY THE CCPA WITHIN THE PAST 12 MONTHS. ALSO, WE HAVE NOT “SHARED” PERSONAL INFORMATION WITH THIRD PARTIES FOR THE PURPOSE OF CROSS-CONTEXT BEHAVIORAL ADVERTISING.
Rights for California Minors
Minors under the age of 16 have the right to request the deletion, correction, or copies of information publicly posted by you, such as on forums or bulletin boards.