Privacy Policy
- About this Privacy Policy
- Who we are
- How to contact us
- What information we collect
- Linking to third party websites
- Why we collect, process and use your information
- How long we keep your information for
- Your rights
- Sharing your information
- Changes to this Privacy Policy
- Children's privacy
- Your California privacy rights
- Cookies
- Security
- Where your information is transferred and stored
- Legal bases for processing your information
Our Privacy Policy applies to any user of our games platform, related services and websites.
We care about your privacy and we think it is important that you always know what information we obtain about you in the context of your use of the Smilegate Entertainment website and community and what that information is used for. In the Privacy Policy below, we therefore aim to keep you fully informed as to the type, extent and purpose of the collection, storage, use and processing of personal data on our gaming platform, PC games, mobile game apps, websites, mobile platforms and online communities and/or services relating to the Smilegate Entertainment online community and related services and software (the "Services") and the Smilegate Entertainment website on which this Privacy Policy is posted (the "Websites").
Personal data is all information relating to an identified or an identifiable natural person. A person is identified when the identity of a specific person can be deduced from the information itself. A person is identifiable when we can make a connection to a specific person using additional information available to us.
This Privacy Policy applies to the Services and Websites only. You can also see this Privacy Policy at the Websites. We recommend that you read the privacy policy of every other service provider you make use of, in particular before you make your personal data available to them.
Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.
IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT DOWNLOAD, REGISTER WITH, OR USE OUR SERVICES OR VISIT OUR WEBSITES.
By downloading our games, visiting our Websites and using our products and services (including the Services), you acknowledge the terms of this Privacy Policy and the use and disclosure of your personal data as set out in this policy.
If you are using Services in specific countries or regions (for example, when you use services in Republic of Korea), please refer to our Privacy Policy applied in each country.
We are a provider of a game platform and related services and applications.
We are Smilegate Entertainment, Inc., located at 2F, Solid Space Building, 220, Pangyo-ro, Bundang-gu, Seongnam-si, Gyeonggi-do, 13493, Republic of Korea (hereinafter: "SGE" "Smilegate Entertainment" "we" or "us").
We are the provider of the Services and the Websites and the organization responsible for the personal data you provide as part of using the Services and the Websites within the meaning of applicable data protection and privacy laws.
You can contact our dedicated privacy contacts with any queries or complaints regarding your data.
If you have any questions about this Privacy Policy or our use of your personal data, if you need to report a problem, or if you would like to exercise one of your rights under this Privacy Policy you can contact us using the following contact details:
Title: Data Protection Officer
Email: sge_contact@smilegate.com
For the purposes of applicable EU data protection legislation, we also have a representative located within the European Union. The contact details of our EU representative are set out below:
Name: v. KEUSSLER Consulting GbR
Address: v. Keussler Consulting GbR, partnership,
Schepp Allee 47, 64295 Darmstadt, Germany
Email: privacy_EU@smilegate.com
4. What information we collect
We collect certain information about you when you use our Services
We collect the following types of information about you:
- When you contact with any queries or complaints regarding Sierra Squad: email address
- When you use our Services or the Websites:
- service usage records, IP information, country, PC specifications information and device information(OS, model name, identifiers such as UUID, advertising identifier);
We log your visits and use of our Services using cookie technology.
Some of the information described above is collected automatically, using cookies or mobile cookies (pieces of data sent by a website to your computer and stored on its hard drive or a small file placed on your smartphone). See below for more information about how we use cookies.
We also use tracking analysis tools in our Services and Websites that utilize cookies and similar mechanisms.
Where processing is necessary for us to carry out our legal obligations
We have legal obligations that we need to comply with, and we are allowed to collect your personal data when we need to comply with those legal obligations.
IF YOU DO NOT WANT US TO COLLECT ANY OF THE INFORMATION DESCRIBED IN THIS SECTION, DO NOT REGISTER WITH, OR USE OUR SERVICES, OR VISIT OUR WEBSITE.
5. Linking to third party websites
Other websites and applications may use your data differently and have their own privacy policies. You should always read those policies.
Within the Websites or the Services, you may be provided with the option to link through to other websites and services. These other domains, apps and websites are subject to their own privacy practices and we encourage you to read the privacy policies of each and every website and application with which you interact. You visit these other websites or applications at your own risk.
6. Why we collect, process and use your information
We use your data to provide you with our Services.
We collect, process and use your personal data for the following purposes:
We use your data to help deal with complaints.
- to manage and handle complaints, which may include resolving dissatisfaction arising from service use
- to provide customer support
7. How long we keep your information for
We don't keep your data forever.
We will not keep your personal data for longer than the term that is necessary for the purposes for which we collect it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation). When it is no longer necessary the retain your data, we will delete the personal data that we hold about you from our systems.
You have a number of rights regarding your data. These may vary depending on your location.
You have various rights in relation to the data which we hold about you. To get in touch with us about any of your rights under applicable data protection laws, please use the contact details set out above. We will seek to deal with your request without undue delay, and in any event within any time limits provided for in applicable data protection law (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
In addition, for users located in the EU only, the European General Data Protection Regulation (the "GDPR") gives you the following rights in relation to your personal data:
Right to object
This right enables you to object to us processing your personal data where we do so for one of the following reasons:
- because it is in our legitimate interests to do so (for further information please see the section on our legal bases for processing below);
- to enable us to perform a task in the public interest or exercise official authority;
- to send you direct marketing materials; or
- for scientific, historical, research, or statistical purposes.
Right to withdraw consent
Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.
Data Subject Access Requests
You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
Right to erasure
You have the right to request that we "erase" your personal data in certain circumstances. Normally, this right exists where:
- The data are no longer necessary;
- You have withdrawn your consent to us using your data, and there is no other valid reason for us to continue;
- The data has been processed unlawfully;
- It is necessary for the data to be erased in order for us to comply with our obligations under law; or
- You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so. When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
Right to restrict processing
You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
Right to rectification
You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Right of data portability
If you wish, you have the right to transfer your personal data between service providers. In effect, this means that you are able to transfer the details we hold on you to another third party. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you.
Right to complain
You also have the right to complain to your applicable data protection authority. Contact details for data protection authorities in the EU are available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
In addition, for users located in China only, you will have the following rights in relation to your personal data:
Data Subject Access Requests
You may ask us for a copy of the information, we hold about you at any time, including the personal data, the type or source of such information, the purposes for processing, the identity or type of third parties that have obtained such information. We will provide access to the information we hold about you free of charge, unless we are permitted by law to charge a fee. If you request further copies of this information from us, we may charge you a reasonable administrative fee. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
Right to rectification
You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort.
Right to erasure
You have the right to request that we "erase" your personal data in certain circumstances. Normally, this right exists where:
- We have violated the applicable laws and regulations or our agreement with you in collecting and using your personal data;
- We have violated the applicable laws and regulations or our agreement with you in sharing or transferring your personal data with or to third parties, in which case we will notify the third parties to erase your personal data; or
- We have violated the applicable laws and regulations or our agreement with you in publicly disclosing your personal data, in which case we will cease the public disclosure and notify the recipient to erase the personal data.
Right to withdraw consent
Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), including collecting, sharing, transferring or publicly disclosing your personal information, you may withdraw this consent at any time and we will cease to use your data for that purpose.
Right of data portability
If you wish, you have the right to transfer to another third party the basic information and identity information we hold on you.
To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you to the extent permitted by then commonly-employed technology.
We may share your data with limited third parties (e.g. to help us provide the Services)
In general, your data is processed exclusively by us and we do not pass on any personal user data to third parties unless it is necessary to do so in order to offer you our Services. Where we do share your personal data, we do so with the following categories of recipients:
Related entities
We share your data with certain other entities within the Smilegate group, such as Smilegate Entertainment, Inc. These entities use your personal data for the purposes of providing their own services (including games) to you. Their use of your personal data is subject to their own privacy policies. For further information on how these Smilegate entities process your personal data, please review those privacy policies.
Service Providers
In order to provide the Services we work with certain service providers (e.g. payment service providers, Solution providers, Customer Support service providers) who may, in the course of providing the respective services, receive and process personal data on our instruction and on the basis of a commissioned data processing agreement. In addition, we use certain software tools, including in relation to anti-cheat and fraud prevention analytics, which may allow the software provider to collect certain information for the purposes of providing the relevant services.
Regulatory bodies
We may disclose your personal data:
- to data protection regulatory authorities;
- in response to an enquiry from a government agency; and
- to other regulatory authorities with jurisdiction over our activities.
Professional advisors and Auditors
We may disclose your personal data to professional advisors (such as legal advisors and accountants) or auditors for the purpose of providing professional services to us.
Replacement providers
In the event that we sell or buy any business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If Smilegate Entertainment or substantially all of its assets are acquired by a third party, personal data held by us about our clients will be one of the transferred assets.
Please see the "Cookies" section, below for further information on the cookies which are used as part of the indicator and tracking analysis tools in the websites.
At your option
In certain circumstances, you have the option of sharing information with others yourself as part of the Games (e.g. if you give out personal data in a publicly accessible player or forum profile). However, we do not transfer such data to other third parties.
For example, within the Games and the Websites, you may be provided with the option to link through to other websites. These other domains, apps and websites are subject to their own privacy practices and we encourage you to read the privacy policies of each and every website and application with which you interact. You visit these other websites or applications at your own risk.
You should be aware that personal data that you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your data and by using such services, you assume the risk that the personal data you provide may be viewed and used by third parties for any number of purposes.
Otherwise, your data will only be passed on in special exceptional cases, where we are obligated or entitled to do so by law or upon binding order from a public authority.
10. Changes to this Privacy Policy
Changes to this Privacy Policy apply to your use of our Services after the “effective date.”
We will review this Privacy Policy periodically, and reserve the right to modify and update it at any time. You acknowledge that we may make changes to this Privacy Policy and it is your responsibility to check back to this page from time to time to review the Privacy Policy; provided, however, that if such changes are significant and it is required by applicable laws, we will endeavour to post notice or acquire your consent regarding such significant changes to this Privacy Policy. Changes to this Privacy Policy will come into effect immediately upon such changes being uploaded in the Services or to our Websites.
THE SERVICES ARE NOT INTENDED FOR CHILDREN.
12. Your California privacy rights
If you are located in California, you have certain additional rights.
California Civil Code section 1798.83 permits users who are California residents to request certain information identifying any third party to whom Smilegate Entertainment may have disclosed, within the past year, personal data pertaining to such user and such user's family for that third party's direct marketing purposes, as well as a description of the personal data disclosed. To request such information, you may contact us using the contact details set out above. Any written inquiry must include "California Privacy Rights Request" in the first line of the description. Please note that we are only required to respond to one request per user each year.
If the California Consumer Privacy Act (CCPA) applies to your information, you can exercise your rights to receive information about our data practices, as well as to request access to and deletion of your information. See the ‘Your rights' section above for more information.
In addition, California residents under the age of 18 who are registered users of any of online sites, services or applications where this Privacy Policy is posted may under California law request and obtain removal of content or information they have publicly posted. To make such a request, you may contact us using the contact details set out above. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Do Not Track
California law permits our users who are California residents to be informed as to how we respond to web browser "Do Not Track" settings. We do not respond to "Do Not Track" settings at this time, whether that signal is received on a computer or on a mobile device.
Do Not Sell My Personal Information
The California Consumer Privacy Act (CCPA) provides residents of the State of California the right to opt out of the sale of their personal information. If you wish to opt out of the sale of your personal information, you can either click on the "Do Not Sell My Personal Information" button or send an email to privacy_stove@smilegate.com.
We use cookie technology to provide a personalised service to you and for analytics and tracking purposes.
We use cookies (access data files) which save the user's personal information in order to provide a specialized service that is customized and personalized to our users, as well as for analytics and tracking purposes. Cookies are small pieces of data (text files) that are sent by the website server to the user's browser or app and saved on the user's computer and other devices. With respect to its operation, our cookies distinguish between the users' computer or mobile phones but do not differentiate the individual users.
You have a right to choose whether the cookies are installed or not. You may choose to refuse all cookies, confirm each time a cookie is saved, or permit all cookies by going to [Browser Setting], or by using the Settings or Options function on mobile devices. However, if you refuse all cookies, you cannot use our services that use cookies.
[Browser Setting]
- Edge : Select "Settings" menu at the top right side of the browser > "Cookies and site permissions" > Cookies and data stored
- Chrome : Select "Settings" menu at the top right side of the browser > "Privacy and security" > Cookies and other site data"
- Internet Explorer : Select "Tool" menu at the top of the browser > "Internet Options" > "Personal Data" Tab > Settings
We take security seriously and put in place measures to protect your information
We have in place appropriate technical and organizational security measures to protect your personal data, including:
• In order to protect the unauthorized disclosure of users' personal data from hacking or any external break-ins, we use equipment that blocks any external break-ins, which protects the data from any hacking, attacks, or unauthorized access, and we also use encryption, etc., so that personal data may be transferred safely. In particular, the server containing users' personal data is managed separately so that is not directly linked to the external internet line.
• In preparation for any unexpected emergencies, we have a policy to back-up the system and data.
We are taking protective measures to try and minimize damages caused by computer viruses by using vaccine that are regularly updated.
Only the minimum number of people have right of access to the users' personal data.
We regularly train our staff who handle personal data on new security technology and personal data protection obligations. Further, through an internal designated personal data protection unit, etc., we try and correct any errors immediately upon detection by checking the company's personal data processing procedure implementation and the relevant personnel's compliance with the personal data protection policies.
15. Where your information is transferred and stored
We may store, transfer and use your data outside your country.
In the event that we transfer your personal data to another country and where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that any such transfers is undertaken in accordance with applicable data protection and privacy laws and that your data is treated securely and in accordance with this Privacy Policy. However, please note that where personal data is stored in another country, it may be accessible to law enforcement agencies in accordance with domestic laws.
| Data Consignment Details | |
| Smilegate West, Inc. *Kayako Cloud, Inc. | · Purpose of Data Transfer (Smilegate West) Customer support for Crossfire Sierra Squad (Kayako Cloud) Development and maintenance of customer support solutions |
| · Transferred Data: Email address | |
| · Transfer Country, Date, and Method: Data will be transferred to Smilegate West (Canada) and Kayako Cloud (United States) over the network when the service is used. | |
| · Consignee Contact Information (Smilegate West) privacy_EU@smilegate.com (Kayako Cloud) privacy@kayako.com. | |
| · Transferred Data’s Retention and Usage Period: Data will be stored until the end of the consignment agreement unless otherwise prescribed by other laws and regulations. |
16. Legal bases for processing your information
We rely on certain lawful bases to collect, use and share data about you if you are in the EU.
For users located in the EU only, the GDPR requires us to inform you of the different legal bases that we rely on to legitimize our processing of your personal data. We have described these below.
Where you give us your consent to process your personal data
We are allowed to use your personal data where you have specifically consented. In order for your consent to be valid:
- It has to be given freely, without us putting you under any type of pressure;
- You have to know what you are consenting to – so we'll make sure we give you enough information;
- You should only be asked to consent to one thing at a time – we therefore avoid "bundling" consents together so that you don't know exactly what you're agreeing to; and
- You need to take positive and affirmative action in giving us your consent – for example, we could provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
We currently seek your consent for marketing and advertisement purposes.
Before giving your consent you should make sure that you read any accompanying information provided by us so that you understand exactly what you are consenting to.
You have the right to withdraw your consent at any time, and details can be found in the "Right to withdraw consent" paragraph in the section on your rights above.
Where processing your information is within our legitimate interests
We are allowed to use your personal data where it is in our interests to do so, and those interests aren't outweighed by any potential prejudice to you.
We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to:
- To handle customer complaints;
- To verify your identity;
- To ensure that our systems run smoothly;
- To protect against improper use or unauthorized use of our Services;
• To market our Services; and
We don't think that any of the activities set out above will prejudice you in any way. However, you do have the right to object to us processing your personal data on this basis. We have set out details regarding how you can go about doing this in the section on your rights above.
Where processing your personal data is necessary for us to carry out our obligations under our contract with you
We are allowed to use your personal data when it is necessary to do so for the performance of our contract with you. For example, we need to process certain personal data about you in order to be able to provide you with related services (including Games branded websites) which you have requested from us and in order to govern the relationship between you and Smilegate Entertainment.
Where processing is necessary for us to carry out our legal obligations
As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with, and we are allowed to use your personal data when we need to comply with those other legal obligations.
This Privacy Policy should come into effect from Sept. 29, 2023