Privacy Policy

1. PURPOSE

“MMD” (hereinafter referred to as ‘the company’) values the personal information of users and notifies the method/purpose of using the personal information (operating program, website, etc.) of users collected when using the service. The company complies with the actions being taken to protect personal information and the following details:This policy was established in accordance with Korea's Personal Information Protection Act, and the company does its best to provide services in compliance with international standards.

This personal information handling policy contains the company's various policies on personal information protection, and the company discloses the personal information handling policy so that users can easily check it at any time in accordance with the regulations of the law. This personal information handling policy is subject to change due to changes in related laws and guidelines or internal policies of the company.

2. COLLECTION AND USE OF PERSONAL INFORMATION

1) COLLECTION OF PERSONAL INFORMATION

The company collects the information necessary for service provision as follows after obtaining users consent.

※ Mandatory information: Minimum information to be collected to perform essential functions of basic service

※ Optional information: Information additionally collected to provide additional services

Division	Collection • use purpose	Mandatory/Optional	Collection and use item
Membership signup	Membership signup	Mandatory	Facebook	Information provided to Facebook, profile image URL, random number, ID
			Google	Information provided to Google, profile, URL, random number, ID
			Apple	Information provided to Apple, profile, URL, random number
Identity verification	Identity verification	Mandatory	Name, DOB, gender, Korean/Foreigner, mobile carrier information, mobile phone number, connection information (CI), duplicate subscription information (DI)
	Check legal representative	Mandatory	Name, date of birth, gender, domestic and foreign information, mobile carrier information, mobile phone number, connection information (CI), duplicate subscription information(DI)
		Optional	Identification of legal representative
Event	Event participation	Optional	E-mail address, mobile phone number, social media ID, and information required for event participation
	Event winning	Mandatory	E-mail address, mobile phone number, social media ID, and information required for event participation
	Check duplicate participation	Optional	Advertising identifier, service use record, cookie
Marketing	Pre-booking	Optional	Email Address
	Information on new services and newsletters	Optional	Email address, mobile phone number, social media ID
	Customized ad	Optional	Ad identifier, service use record, cookie
Customer service	User identification and contact	Mandatory	Email address, nickname or nickname identification, mobile phone number
	Check consultation contents	Optional	ID, nickname, and other information necessary for consultation (mobile carrier information, purchase history, gift certificate number, other payment information)
Payment	Check payments, cancellation and refunds	Mandatory	Payment market information, receipt information, payment time, and other payment information
Service provision	Personal location information	Optional	Search for location information
	Other information	Mandatory	Service use records, access and game logs, payment records, IP address, mobile phone number, mobile device model name, carrier information, OS information and version, device identifier, terminal language, and country information

When linking accounts through external platforms, the company can receive IDs, nicknames, profiles, and link key values, but it collects and uses only link key values.

※ Type of external platform: Facebook, Naver, Kakao, Google, Apple, Twitter

The following information may be collected in the process of using the service.

- IP information, game, and service usage log, access log, transaction record, usage limit record, game version

- Mobile device information: model name, mobile carrier information, OS information, language and country information, device serial number, advertising ID, cookie

- PC: CPU, memory, storage, VGA, MAC information, cookie

The company can collect additional information when users use related services, collect personal information, and obtain users consent according to the law.

- Customer service: server name, clan name, mobile device name, OS version, transaction date, transaction account, order number, item name, transaction amount, IP address, web browser information

- Participation in events and promotions: server name, nickname, clan name, contact information

- Winning events and promotions: name, contact number, personal identification number

If it is necessary to collect personal information, such as users’ registration for children under the age of 14, information such as the name and contact information of the legal representative may be collected to confirm the legal representative's consent. If the legal representative disagrees, the information is destroyed.

The following information may be automatically collected when using the service to secure service stability, prevent fraudulent users, customize advertisements, and identify users.

* IP address, cookie, date and time of visit, service use record, bad use record, device information (model name, carrier information, OS information and version, device identifier, terminal language and country information, advertising identifier (can agree to collection or reject automatic collection), PID (random value generated when running the app)

2) PERSONAL INFORMATION USE

The company uses the collected personal information for the following purposes.The personal information handled by the company is not used for any purpose other than the following information accessed by the members' request and consent will be transferred overseas according to the attributed access authority for smooth service operation, customer consultation, and game service management. The information transferred overseas is safely protected under the Personal Information Protection Act, the Law on Promoting Information and Communications Network Utilization and Information Protection, Etc.

Type	Details
Transmission	MMD
Transmission	Manager: Mark Choi
Transferred country	Korea
Transmission method	When receiving customer service inquiries
Transmission purpose	Quality improvement of game service through customer complaints, dispute mediation, system operation and management
Transferred items	Member identification, nickname identification, service use record, payment receipt record
Period of use of transferred information	Up to three (3) years according to the law on consumer protection in e-commerce, etc.
Period of use of transferred information	or destroy upon termination of service

3. CONSIGNMENT AND PROVISION OF PERSONAL INFORMATION

1) PERSONAL INFORMATION CONSIGNMENT

The company consigns the following personal information to improve service In accordance with the relevant law, personal information is managed and supervised so that it can be safely handled when signing a contract, and it is prohibited to consign to another company without the prior approval of the company.

- Target : MMD

Purpose: marketing and events, event operation, inquiry response

2) Personal information provision

The company provides personal information to other companies after obtaining consent from users so that they can use various services. It is required to notify users before providing personal information, except when it is regulated in the relevant law, and handle it with consent. However, personal information may be provided in the following cases

- Where data provision is compulsory in accordance with the regulations of the law or when there is a request from a court, investigative agency, or other administrative agency in accordance with due process

- Where it is necessary to settle charges according to service provision

- Where it is necessary for statistical preparation, academic research, or market research, and has been handled so that a specific individual cannot be identified

4. Retention and destruction of personal information

1) In principle, the company destroys personal information without delay after the purpose of collection and use is achieved. However, if it is necessary to preserve it by regulation of the relevant law, such as Commercial Law, Consumer Protection Law in E-Commerce, Etc., the company will keep users’ information for a certain period determined by the relevant law. In this case, the company uses the information it keeps for its purposes only, and the retention period is as follows.

Law and Regulation	Type	Retention Period
Law on Promotion of Information and Communications Network Utilization and Information Protection, Etc..	Records on identity verification, login information	1 year
Protection of Communications Secrets Act	Records of access to services	3 months
Consumer protection law in e-commerce, etc.	Records on consumer complaints or dispute handling	3 years
Commercial law, consumer protection law in e-commerce, etc.	Records on the conclusion or withdrawal of contracts, etc.	5 years
Commercial law, consumer protection law in e-commerce, etc.	Records on payment and supply of goods, etc.	5 years

2) Destruction procedure.

The collected information is moved to a separate DB after the purpose is achieved (separate filing cabinet in case of paper) and stored for a certain period according to internal policy and information protection reasons according to other relevant laws (refer to retention and period of use) and then destroyed. This personal information is not used for any purpose other than to retain it unless it is by law.

3) Destruction method

- The personal information printed on the paper is crushed by a grinder or destroyed by incineration.

- The personal information stored in electronic file formats is deleted using technical methods that cannot be reproduced.

5. RIGHTS OF USERS AND LEGAL REPRESENTATIVES AND HOW TO EXERCISE THEM

1) INFORMATION COLLECTION AND INFORMATION PROTECTION OF MINORS

According to the law, the company does not collect personal information of a specific age group, and that age group cannot play this game. The company can immediately delete the personal information of minors and take legal action if it is collected and used.

- If a correction for an error in users’ personal information is requested, the company will not use or provide the personal information until the correction is completed. Also, if the wrong personal information has already been provided to a third party, the company will notify the third party of the correction handling result without delay so that the correction can be made.

- Withdrawal of consent or expiry of the legal representative agreement will be destroyed in a way that cannot be reproduced 30 days after the purpose of use expires. However, if it is necessary to preserve it by regulation of the relevant law, such as Commercial law, consumer protection law in e-commerce, etc., the company keeps the personal information of the legal representative for the period prescribed by the relevant law.

- To inquire/modify users' or minors' personal information, change personal information (or modify 'users’ information,' etc.), or cancel (withdrawal of consent), you can click "User withdraw" to go through the identification process and view, correct, or withdraw directly. Or, if you contact the personal information manager in writing, by fax, or by e-mail, the company will act without delay.

2) Matters concerning the management of users’ own personal information

- Users may withdraw their consent to personal information collection by writing, calling, or e-mailing the person in charge of personal information management. The company takes necessary measures, such as destroying the relevant personal information.

- If users’ representatives visits and request for inspection or correction, the company may check whether the person is an actual users’ representatives, and in this case, the company may request to present a certificate indicating the representation relationship.

- If there is a justifiable reason to refuse the request for access or correction of all or part of users’ personal information, the company shall notify users without delay and explain the reason.

- If users request correction or deletion of their personal information, the company will take necessary measures without delay after confirming their identity.

- The company handles personal information that has been canceled or deleted at the request of users or their legal representatives as specified in the “retention and use period of personal information” and handles it so that it cannot be viewed or used for any other purpose.

6. ANALYSIS AND REJECTION OF SERVICE USE RECORDS

The company uses users' advertising identifiers and analytics software to provide users with more suitable and useful services.

Like Android ad IDs, Apple ad IDs, etc., ad identifiers can be denied or reset for advertisements based on interest and are not used to connect with personal information or to identify individuals by changing the device's settings to non-permanent and non-personal identifiers. Analytics software is used to analyze information generated automatically when users visit the website or use mobile services, which users may opt out of.

1) COLLECTION OF PERSONAL INFORMATION BY COOKIES

- What are cookies?

Cookies are very small text files that the server used to run the site sends to users' browsers, which can be stored and used on users' computers.

- How to reject cookie settings?

∙ Chrome: Settings menu on the right > Advanced Settings At The Bottom > Personal Information Content Settings > Direct Settings

∙ Internet Explorer: Tools Menu > Internet Options > Personal Information > Direct Settings

2) Collection of personal information by online customized advertisement Advertisers are allowed to collect behavioral information.

- Advertising business

Google, Facebook, Twitter, ClickMon, TargetingGates, RealClick, Criteo, AdJust, Tune, AppsFlyer, adbrix, Admob, Unity Ads, AdColony, Tapjoy, MOLOCO, etc.

- behavioral information collection method: Automatically collect when users visit the site or run the app

- Refusal to the collection by ad identifierp

∙ For Android, [Settings > Google > Advertising] or [Settings > General > Accounts & Sync > Goolge > Personal Information and Personal Information Protection > Advertising Settings]

∙ For iOS [Settings > Personal Information > Advertising]

- Refusal to the analysis of service use records

∙ In the case of Internet Explorer, go to the Tools menu at the top of the web browser > Internet Options menu > Advanced Menu > Security Menu > Check "Do not send trace requests to sites visited by Internet Explorer"

∙ In the case of Chrome, select the menu at the top right of the web browser > Select Settings > Personal Information and Security Menu > Cookies and other site data Menu > Activate 'Do not track' with discovery traffic

7. TECHNICAL/ADMINISTRATIVE PROTECTION MEASURES FOR PERSONAL INFORMATION

The company endeavors to ensure that personal information is not lost, stolen, leaked, falsified, or damaged and to ensure safety in handling users' personal information.

1) TECHNICAL MEASURES

Data is backed up from time to time to prevent damage to personal information, and the latest vaccine program is used to prevent users' personal information or data from being leaked or damaged. Through encryption algorithms, etc., personal information can be safely transmitted on the network. The company also uses intrusion prevention systems to control unauthorized access from the outside and tries to have all possible technical devices to ensure systematic stability.

2) ADMINISTRATIVE MEASURES

The company limits the handling of users' personal information to the person in charge, assigns a separate password for this purpose and regularly renews it, and always emphasizes compliance with the company's personal information handling policy through regular training for the person in charge. And we regularly check the implementation of the company's personal information handling policy and whether the person in charge complies with it so that if a problem is found, we can immediately modify and correct it.

However, the company is not responsible for any problems caused by the leakage of personal information such as IDs and passwords due to users' own carelessness or Internet problems.

8. TRANSMISSION TO A THIRD PARTY'S WEBSITE

The company may provide users with links to third-party websites or resources. In this case, the company has no control over external websites and third-party's materials. The personal information handling policy and terms of use of the website are irrelevant to the company, so please check the policy of the website you visited to prevent any disadvantages or material damage. You are solely responsible for this.

9. CALIFORNIA CONSUMER PERSONAL INFORMATION PROTECTION ACT

The company complies with the California Consumer Personal Information Protection Act.

1) Personal information collected and shared for business

The company may collect and share information that can directly or indirectly identify users or their devices, information (hereinafter referred to as "personal information") that can reasonably be associated with users, and information about their devices as follows. Identifier: nickname, unique identifier, online ID, IP, email address, account name, or other similar ID Commercial information: records of purchase/acquisition/collection items or service history, other purchases, consumption history, or preference Geographic location data: location information such as country of residence

2) COLLECTION

The company uses and shares the following personal information for Service quality improvement, service provision, account maintenance, customer reception, customer verification, advertisement, user analysis, etc.

- Resolving technical issues and improving the quality of service of the company

- Identification of the person to provision the company service

- Technical protection against unauthorized programs related to the company service - the company service Prevent inappropriate gameplay that may negatively affect other users

- Provide customer support for the company service by collecting and answering customer inquiries

- Forum providing services by the company website

- Use to provide information about the company events and surveys, for opportunities to participate in the company events and surveys, and other marketing and promotional purposes of the company

- Usage pattern tracking, user trend analysis, the company service usage statistics calculation

3) PROHIBITION OF SELLING PERSONAL INFORMATION

The company does not “sell” the information of customers who use the services of the company for financial or special profit of the company.

4) NONDISCRIMINATION.

Some features of the company service may be stored or no longer provisioned, but the company does not discriminate against users exercising their rights under the CCPA.

5) CALIFORNIA CONSUMER PRIVACY ACT

(1) California residents have the right to hear the identity of the company or the Customs Service that uses their personal information for marketing purposes and the extent of the personal information used.The company provides the following information after receiving a request for disclosure of information that meets the requirements.

- Items of requester's personal information collected by the company in the last 12 months.

- Scope of sources from which personal information was collected in the last 12 months

- Items of personal information shared by the company with the Customs Service

- The company's business/commercial purpose of collecting and sharing selected personal information

- Personal information of specific users collected by the company in the last 12 months

- In the case of disclosing personal information of users for business, the company specifies the scope of personal information to be collected, collection and use method, etc.

(2) If users are California residents, they have the right to request the deletion of personal information collected and in our possession, , subject to certain exceptions. The company receives and confirms the user's request, and if it is not an exception to CCPA, it will destroy the users’ personal information.

10. PERSONAL INFORMATION ACCORDING TO GDPR

The company's handling of personal information is legal only if it pertains to one or more of the following.

1) Where users consent to personal information handling.

2) Where handling is necessary before signing the contract for the performance of the contract to which users are parties or for measures requested by users:

- Membership management, identity verification, etc.

- Fulfillment, payment, and contract conclusion regarding service provision requested by users

3) Where handling is necessary to comply with legal obligations to which the company applies;

- Compliance with relevant laws, legal procedures, and governmental requirements

4) Where it is necessary to protect the important interests of users or other individuals when handling.

- Detection, prevention and response to fraud, abuse, security risks, and technical problems that may harm users or other individuals

5) Where handling is necessary for the performance of tasks that consume public power belonging to the public interest of the company

6) Where handling is necessary for the legitimate benefit pursued by the company or a third party. (Except when the interests or basic rights and freedoms of data subjects that require personal information protection, such as children, take precedence over those interests.)

RIGHTS OF USERS UNDER THE GDPR

Users or legal representatives can exercise their rights against the company to collect, use, and share personal information as a subject of the information. More information can be found in Article 12 (the rights of users and legal representatives and how they are exercised). To request a right, please send an e-mail to mark@idlesoulsavers.io.

11. CONSIGNMENT OF PERSONAL INFORMATION HANDLING

The company may consign personal information to improve service. Relevant law regulates matters necessary to manage personal information during consignment contracts safely. The contents of the company's personal information and consignment work are as follows.

Name of consignment agency: Mark Choi

Consignment task: game management agency service

Consignment period: consignment contract until membership withdrawal or termination

Country: South Korea

12. PERSONAL INFORMATION PROTECTION MANAGER

Members can report all complaints related to personal information protection that occurred through the company's service to the personal information protection manager or the department manager. The company responds quickly and sufficiently to users' complaints.

Personal information protection manager

Name: Mark Choi

E-mail: mark@idlesoulsavers.io

13. OTHERS

The company's personal information handling policy may change from time to time. When changes in law and guidelines or changes in the company's internal policies occur, members should check the contents frequently when visiting the official community (social media). When the company revises the personal information handling policy, it will notify the change in a way that other members can check, such as the official community (social media) or the initial screen of the service.