PIVOT Games Privacy Policy

Last updated on 22th of August 2023

 

A quick summary: this document explains

a.   what information we and our partners collect when you use PIVOT Games’ games and

services

b.   where that information is stored and how it is protected

c.   how we use that information

d.   how long we retain that information

e.   your rights in relation to that information

This Privacy Policy explains to you how your personal information is

collected and stored and what happens to it regarding the PIVOT

Games Services. Because we know legal wording is not much fun,

we have included a short and informal summary of each section

(but the full version is the legally binding one). If you have any queries

you can contact us at pivotgameshelp@gmail.com.

 

1.     WHO WE ARE AND WHAT THIS PRIVACY POLICY GOVERNS 

This Privacy Policy explains the different kinds of information PIVOT Games can collect

from you when you're using the PIVOT Games Services. Legally, we cannot and will not

collect personal information about children below 13 without parental/guardian

involvement. We will comply with applicable privacy laws, including the EU’s GDPR.

 

1.1.      About Us. We are PIVOT Games Inc. (incorporated and registered in South Korea with

company number 1138681375) of 54, Changeop-ro, Sujeong-gu, Seongnam-si, Gyeonggi-do,

Republic of Korea.

1.2.  Which services does this Privacy Policy apply to? All of our video games, our websites,

user accounts, customer and technical support, official forums, wikis, blogs, social media

services and other products and services - “PIVOT Games Services” for short.

1.3.  What information does this Privacy Policy apply to? Specifically, this Privacy Policy

governs personal data (or, in the USA, personally identifiable information) and applicable non-

personal information (or, in the USA, non-personally identifiable information), which we collect

from you when you are using the PIVOT Games Services ("personal data" means information

which, on its own or in combination with other information, can be used to identify you).

1.4.  What about children? We recognize we have a special obligation to protect personal

information obtained from children. Legally you must be at least 13 years old to use the PIVOT

Games Services (but this might be older depending on whether or not a particular PIVOT

Games Service has a required minimum age rating) as per our Terms of Service. We do not

knowingly collect personal information from any child under the age of 13 without consent from

their parent or guardian. If you are a parent or guardian and are concerned about the transfer of

personal information about your child, please contact pivotgameshelp@gmail.com.

1.5.  What about GDPR? We respect your right to privacy and will only process personal

information in accordance with applicable legislation in the EU (which includes the General Data

Protection Regulation (EU) 2016/679 or the GDPR as it is often referred to), the USA and

elsewhere. For personal information contained in this Privacy Policy which is used by PIVOT

Games in connection with the PIVOT Games Services, PIVOT Games is the data controller

under EU data protection legislation.

 

2.     WHAT INFORMATION IS COVERED? 

We may collect certain information when you use the PIVOT Games Services such as

your name and email address (more information below). We do not receive or store your

payment details. Please also read our Cookie Policy.

What information might we collect from you?  When you sign up for, download, use or

play the PIVOT Games Services then we will collect certain information from you. The

information that we collect varies depending on the particular PIVOT Games Services used,

but this may include:

a.   Technical Details. When you use, play or access the PIVOT Games Services we or third

parties on our behalf may collect technical details about the device you are using,

including: internet and/or network connection (including IP address); MAC address, any

device identifier; your operating system, browser type or other software; and your

hardware or other technical details.

b.   Your Activities. When you use, play or access the PIVOT Games Services we or third

parties on our behalf may collect details of how you use our services, including: metrics

information about when and how you use the services; traffic data; language preferences;

in-game purchases; achievements; scores; gameplay statistics; time spent playing; and

your geographical location data.

c.   Your Communications. If you contact us (e.g. via email or call for customer support) or post

in chat sessions, forums, on our social media pages, or other areas of the PIVOT Games

Services, we may collect and maintain a record of your contact details and the content of

your communications.

d.   User Accounts and Newsletters. To access certain PIVOT Games Services (e.g. games or

forums) you may need to create a user account. Or if you sign up to a newsletter, you will

be asked to provide us with certain information. This will be displayed to you at the time

you start to use the applicable PIVOT Games Services (e.g. when you sign up for a

newsletter) and may include your name, username, age, birthdate, a photo or avatar, email

address, country of residence and contact information.

e.   Third Party Accounts. In certain circumstances (e.g. joining our forums) you may be able to

log into certain PIVOT Games Services via third party accounts (e.g. Facebook, Twitter). If

you choose to do so, you are asked to share certain information with us (the exact

information will depend on the particular third party account displayed to you on the

permissions page when you attempt to log in, but may include your name, location, gender,

birth date, email address, photo, profile URL and friends list).

Some of the information types referred to above may be collected on an aggregated or

anonymised (e.g. hashed) basis, or we may use it or share it in an aggregated or anonymised

way, for research or analysis into the way our services operate and are used.

 

2.2.   What about the storage of payment details? The processing and storage of payment

details is a matter for the relevant platform and the applicable payment methods/processors.

PIVOT Games will not receive, process or store any of your payment details. This is because

the payment transactions themselves are completed through the relevant platforms (e.g.

Apple’s App Store or Google Play) via the user account you have associated with that platform

account. If you make in-game purchases within a PIVOT Games game or product, we are

notified by the payment processor once a transaction takes place but we will not receive any

of your actual payment details.

2.3.   What about cookies? We and third parties on our behalf also collect information about

you via cookies and other advertising tracking technologies. You can find out more about our

use of cookies and such technologies in our Cookie Policy here. The Cookie Policy forms part

of this Privacy Policy.

 

3.     WHERE IS YOUR INFORMATION STORED? 

We will store your information in South Korea where possible. We will do our best to keep

this information secure. No information security system is perfect so please remember to

be careful.

Where will your information be stored?  

The information we hold will primarily be stored and processed in the South Korea. By

submitting your personal information, you explicitly agree to such transfer, storing or processing

of data outside the South Korea. We will take all steps reasonably necessary to ensure that this

information is treated securely and in accordance with this Privacy Policy.

All information we hold is stored on our secure servers which we own or license from appropriate

third parties. We use industry standard procedures and security standards to prevent

unauthorised access to our servers, however no online service or website can be completely

secure, so please protect the account information in your possession as well.

 

4.     HOW IS YOUR INFORMATION USED? 

We will use your information to run, maintain and improve the PIVOT Games Services as

well as to communicate with you (e.g. with newsletters or emails). Sometimes we may

share information with partners in order to run our services.

 

4.1.   How might your information be used?  We may use the information above in order to

(for example):

a.   Perform our agreement with you: provide the PIVOT Games Services to you, including:

to carry out our obligations arising from any contracts between you and us; allow you to

participate in interactive features of the PIVOT Games Services when you choose to do so;

and provide you with communication systems.

b.   For our legitimate commercial interests: monitor the performance of the PIVOT Games

Services and user acquisition; ensure that the PIVOT Games Services are presented in the

most effective manner for you and your device(s); enforce our Terms of Service and other

policies; notify you about changes to the PIVOT Games Services; provide, maintain,

protect and improve the PIVOT Games Services; and to protect PIVOT Games and PIVOT

Games Services users.  

c.   Comply with our legal obligations: where we are required to do so by law; and comply

with intellectual property protection obligations we have under applicable laws including the

Digital Millennium Copyright Act and the E-Commerce Directive.

d.   Based on consent: provide you with marketing information about products or services that

you request from us or which we feel may interest you where you have asked us to do so;

and send you push notifications on mobile devices where you have agreed to this.  

 

4.2.   Will we ever share any of your information with other parties?

a.   We will never share your information with third parties for their own marketing purposes

without first obtaining your consent.

b.   We may engage third party service providers in the course of providing the PIVOT Games

Services to you (e.g. data storage, server hosting, live operation, customer and technical

support, game analytics, advertising etc) which may require them to access your

information on our behalf. We will ensure there are appropriate contractual arrangements

in place with any such third party service providers to protect your information. Those third

parties may also collect some information directly from you (e.g. IP address, unique

identifiers etc) subject to their own privacy policies.

c.   We may work with third party service providers (e.g. ad network and measurement

services) to display advertising on the PIVOT Games Services and to manage our ads on

third party sites. We may share certain information (such as your email address, country of

residence and your age) with third parties so that we can better target ads and content to

you. You can choose to prevent your device’s ad identifier being used for interest-based

advertising by updating the settings on your device and you may be able to opt-out from

the collection of information by some of our advertising partners as further detailed in

our Cookie Policy.

d.   We may share your information within the PIVOT Games company group for the purpose

of providing the PIVOT Games Services.

e.   In the unlikely event of a reorganisation or merger of PIVOT Games we may transfer

personal information to an involved third party who will protect this to at least the same

level as we do in this Privacy Policy.

 

5.     HOW YOU USE YOUR INFORMATION AND THIRD PARTIES? 

You have the option to share your own personal information with other parties, in which

case it will be governed by those parties’ own privacy policies – make sure to take a look

at them.

Please remember that any communications you have via the PIVOT Games Services may

reveal details about you. Also, any information you post publicly will be publicly available to other

people. We are not responsible for your use of any otherwise private personal information which

you make available, or the activities of other users or other third parties to whom you give or

make available your information or content. The PIVOT Games Services may, from time to time,

contain or connect you with third party content or services. Our Privacy Policy does not extend to

external sites or companies, so please refer directly to their privacy policies.

 

6.     DATA RETENTION 

We retain your information for as long as needed to provide the PIVOT Games Services to

you or longer where permitted by law.  

How long do we retain your data for? 
As long as necessary for the purpose for which the data

was originally collected. As detailed below, depending on where you live you may have certain

legal rights to object to our collection and use of your data, but this may mean some or all PIVOT

Games Services become unavailable to you. We also reserve the right to retain your information

as necessary to comply with our legal obligations, resolve disputes, maintain appropriate

business records and enforce our agreements.

7.     YOUR RIGHTS 

You have rights about how your personal information is used, which can vary depending

on where you live. If you have any questions, please contact us

at pivotgameshelp@gmail.com.

 

7.1.  Can you ask us to stop processing your personal information? You have the right to

ask us not to process your personal information for marketing purposes. You can change your

email settings to unsubscribe from email communications. Our Cookie Policy also details how

you can deactivate certain types of cookies and other ad tracking technologies that may be

used in providing certain PIVOT Games Services.

7.2.   What are your rights? Depending on where you live, you may have additional privacy

rights. For example, in the EU (particularly under the new GDPR) you have the right to access

and obtain a copy of your personal data we possess; you have the legal right to ask us to

rectify/correct your personal data; and you may have the legal right to contact us to request

that we delete your personal data from our system. We will use commercially reasonable

efforts to honour your request, but we may decline requests that are unreasonably repetitive,

are disproportionate, infringe the privacy of others or as otherwise permitted by law. Please

note though that by withdrawing your consent or otherwise objecting to certain processing of

your information, certain PIVOT Games Services may no longer function properly or be

completely unavailable to you.

7.3.   Under California law, California residents who have an established business relationship

with us have the right to request certain information with respect to the types of personal

information we have shared with third parties for their direct marketing purposes, and the

identities of those third parties, within the immediately preceding calendar year, subject to

certain exceptions. All requests for such information must be in writing and sent to: PIVOT

Games Ltd at na 826, 54, Changeop-ro, Sujeong-gu, Seongnam-si, Gyeonggi-do, Republic of

Korea. This same California law permits us to provide you, in response to your written request,

with a cost-free means to choose not to have your information shared rather than providing

the above described information. You may exercise that choice by contacting us at the

address above.

7.4.   Who should you contact if you would like to exercise these rights? If you would like

to exercise any of these rights or have any queries regarding them, please

contact: pivotgameshelp@gmail.com.

 

8.     OTHER 

We can change this Privacy Policy, but if we do we will put the changed version online.

Please feel free to contact us if you have any questions with regards to the changes

at pivotgameshelp@gmail.com. Please read our Terms of Service

at http://www.pivotgames.net/conf/Terms_of_Service-En.html

8.1.   Will we ever change this Privacy Policy? Possibly, but if we do we will make the

changed Privacy Policy available online, make reasonable efforts to notify you of this and update

the “Last Updated” date. Once we change the Privacy Policy, it will become legally binding on

you and us 30 days after we post it online. You are welcome to contact us if you have specific

questions about the changes at pivotgameshelp@gmail.com. If you do not agree to those

changes, regardless of whether you email us then unfortunately you must cease using all PIVOT

Games Services.

8.2.   Are there any other documents you should read? We'd also like to remind you that our

Terms of Service has more information about how we operate the PIVOT Games Services

(http://www.pivotgames.net/conf/Terms_of_Service-En.html).