Personal Information Handling Policy (Privacy Policy)
PIVOTGAMES, Inc. (hereinafter
referred to as the "Company) complies with personal information protection
provisions of the applicable laws and makes its best efforts to protect Users'
rights and interests by setting up the Company's personal information handling
policy (privacy policy) (hereinafter referred to as the "Privacy
Policy") based on the applicable laws and disclosing the foregoing Privacy
Policy on the Company's homepage (www.PIVOTGAMES.com).
1. Personal Information the
Company Collects and Method of Collection
A. Personal Information the Company Collects
- Identification numbers
provided through the services of Users' Platform Providers, names or nicknames
of Users, device serial numbers (Device ID or IMEI), Phone Number, Device Brand
Name & Specification, etc.;
- Users' status, time of
visit, records of the use of the services, records of improper use, etc.; and
- Credit card information,
telecommunications service provider information, purchase details, gift
certificate numbers and other payment-related information may be collected.
Additional personal information may be collected in certain cases, such
as the following: E-mail addresses and confirmation on purchase details may be
collected for smooth customer service if a customer requests restoration of
paid Contents and refunds, and real name and proof of family relation may be
collected in order to verify payment by a different person.
B. Method of Collection
- Collection through Users'
voluntary provision in the course of subscription to or use of the services
- Automatic collection through
platforms being in partnership with the Company in relation to the provision of
services
- Collection through automatic
collection system, etc.
2. Purpose of Collection and
Use of Personal Information
A. Performance of
Contract and Payment of Fees
- Provision of basic game
functions, provision of functions of communication among Users (such as
invitation of friends and sending gifts), authentication of User Accounts,
product shipping, billing, payment and collection of fees
B. Member Management
- Member authentication for
the use of membership services, authentication of Users in relation to the
provision of the Game Services, personal identification, prevention of improper
members' misuse and unauthorized use, confirmation on the intent to subscribe,
restriction on subscription and number of subscription, preservation of records
for identity verification and dispute resolution, complaint handling and
delivery of notices
C. Marketing and Promotion
- Development of new services,
application to marketing/advertising, provision of customized services,
provision of services and advertisement display in accordance with statistical
characteristics, verification of effectiveness of services, provision of
promotional event and advertising information as well as the opportunities to
participate therein, and access frequency check and statistics on members' use
of services
3. Period of Retention and Use
of Personal Information
In principle, after the
purpose of the collection and use of personal information is accomplished, the
relevant information will be immediately destroyed; provided that in case that
there is a need to preserve the information pursuant to the Company's internal
policies and applicable laws, the Company will store the information for a
certain period set forth in applicable laws as follows:
A. Grounds for Retention of
Information Based on the Company's Internal Policies
- Records of improper use
(Ground for retention: prevention of misuse, Period of retention: 1 year)
B. Reason for Retention of
Information Based on Applicable Laws
- Records relating to
contracts, cancellation of subscription or the like (Ground for retention: Korean
Act on the Consumer Protection in Electronic Commerce, Etc., Period of
retention: 5 years)
- Records relating to payments
and provision of goods, etc. (Ground for retention: Korean Act on the Consumer
Protection in Electronic Commerce, Etc., Period of retention: 5 years)
- Records relating to customer
complaints or dispute handling (Ground for retention: Korean Act on the
Consumer Protection in Electronic Commerce, Etc., Period of retention: 3 years)
- Records relating to visits
(Ground for retention : Korean Protection of
Communications Secrets Act, Period of retention: 3 months)
4. Procedure and Method of
Destruction of Personal Information
Personal information of Users
will be, in principle, immediately destroyed once the purpose of the collection
and use of the personal information is accomplished. The Company's
procedure and method of destruction of personal information are as follows:
A. Procedure of Destruction
- The information entered by
Users for the subscription to services, etc. will be moved to a separate DB (in
case of paper, a separate document box) after the purpose is achieved, and
destroyed after being stored for a certain period in accordance with the ground
for the information protection under the Company's internal policies and applicable
laws (Refer to periods of retention).
- The said personal
information will not be used for any purpose other than the purpose of
retention unless otherwise prescribed by law.
B. Method of Destruction
- Personal information printed
on paper will be destroyed by shredding through a shredder or incineration.
- Personal information stored
in the form of an electronic file will be deleted through a non-recoverable
technical method.
5. Provision of Personal
Information
The Company, in principle, will
not provide personal information of Users to a third party except for the
following cases:
- In case that Users consent
in advance; or
- Pursuant to applicable laws
or in case of an investigation authority's request for investigation purposes
pursuant to the procedures and methods set forth in laws.
6. Delegation of Collected
Personal Information
The Company delegates certain
operation to outside entities for the performance of services as follows:
- Delegated entity: IGS Co.,
Ltd.
- Delegated matters: Customer
service and support as well as service operation (such as operation of the
relevant community) in relation to the "Hero Sky" game
7. Rights of Users and Their
Legal Representatives and Method of Exercise of Such Rights
- Users may review or change
their registered personal information at any time and request termination of
subscription.
- A User may, after going
through the identity verification procedure by clicking "Change of
Personal Information" (or "Change of Member Information") in
case that the User wants to review and change his or her personal information
and "Membership Withdrawal" in case that the User wants subscription
termination (revocation of consent), directly review and change his or her
personal information or withdraw his or her membership.
- If a User contacts the
person responsible for personal information management in writing, by phone or
by e-mail, the Company will immediately take proper measures.
- In case that a User requests
a correction of an error of the personal information, the relevant personal
information will not be used or provided until the correction is completed.
Further, if erroneous information is already provided to a third party,
the Company will immediately notify the third party of the results of the correction
and have the third party make the correction.
- The Company will handle the
personal information terminated or deleted per a User's request in accordance
with the "Period of Retention and Use of Personal Information the Company
Collects" and prevent any review or use of such personal information for
other purposes.
8. Installation / Operation of
Personal Information Automatic Collection System and Refusal Thereof
The Company may automatically
collect device identification numbers (Device ID, UDID or IMEI) when a User
runs an Application for Game Services in order to generate account information.
Also, in order to provide functions, such as friend registration or
friend recommendation, the Company may automatically collect identification numbers
of Users from Platform Providers and identification numbers related to a list
of friends. If a User does not consent to the automatic collection of
those identification numbers or device identification numbers, Game Services
including friend invitation and sending gifts cannot be properly provided, and
the User will not be able to properly use Game Services of the Company.
9. Measure for Securing Safety
of Personal Information
The Company implements the
following technical / administrative measures for securing the safety in order
for personal information not to be lost, stolen, divulged, altered or damaged
in the course of handling personal information of Users:
A. Measures against Possible
Hacking, Etc.: The Company makes its efforts to prevent divulgence of or
damages to members' personal information due to hacking, computer virus, etc.
The Company frequently backs up records against possible damages to
personal information, prevents divulgence of or damages to personal information
or records of Users, and arranges safe transmission of personal information on
the network through encoded communications, etc. Also, the Company
controls unauthorized access from the outside through an intrusion blocking
system and otherwise makes its efforts to have possible technical equipment for
securing systematical safety.
B. Minimizing Number of
Relevant Employees and Training: Those employees
of the Company who handle personal information are limited to certain people in
charge, and separate passwords for the job are given and regularly renewed, and
the compliance with the Privacy Policy is always emphasized through frequent
training for those people in charge.
C. Operation of Special Team
for Personal Information Protection: The Company, through an internal special
team for personal information protection, etc., checks the compliance with the
Privacy Policy and, in case of a discovery of a problem, makes its efforts to
immediately cure and correct it. However, in case of a problem resulting
from leaking of personal information due to a User's fault or for a reason not
attributable to the Company's willful misconduct or gross negligence, the
Company will have no liability whatsoever.
10. Dealing with "Do Not
Track" Signals (Regarding Online Personal Information Protection Laws of
the State of California of the U.S.A.)
The Company has no particular
operation dealing with "do not track" signals or other similar
technical mechanisms.
11. Contact Information of
Person Responsible for and in Charge of Personal Information Management
You may report a complaint
relating to personal information protection which occurs during your use of the
Company's services to the person responsible for personal information
management or the relevant division. The Company will provide sufficient
responses to Users' complaints in a speedy manner.
Responsible Person in Charge: Youn Mi Lee
Team and Title: CEO
Contact Information(e-mail)
: pivotgamespeople@gmail.com
If you otherwise need to
report or obtain counseling regarding personal information violation, please
inquire of the institutions set forth below.
Korean Personal Information
Violation Report Center (www.118.or.kr / 82-118)
Korean Information Protection
Mark Verification Committee (www.eprivacy.or.kr / 82-2-580-0533~4)
Korean Supreme Prosecutors'
Office Cyber Criminal Investigation Department (cybercid@spo.go.kr /
82-2-3480-3571)
Korean National Police Agency
Cyber Bureau (www.ctrc.go.kr / 82-2-392-0330)
12. Change of Privacy Policy
The Company may change the
Privacy Policy as the applicable laws or the Company's situation changes.
In case of a change of the Privacy Policy, the Company will notify it on
the Company's website (www.PIVOTGAMES.com); provided that in case of a material
change, the Company will notify each User thereof through the notification
method under the Terms of Service, such as by e-mail.