Gravity Neocyon Inc.PRIVACY POLICY(Effective Date: March O1, 2021)Gravity Neocyon Inc.(“Company,” “we”, “us” or “our”) maintains this Privacy Policy (“Privacy Policy”) that summarizes our policies and processes on how we collect, use disclose, transfer and store your personal information. The Privacy Policy applies only to the collection, use and storage of personal information that you, EXCLUDING a European User (defined as hereinafter), may decide to provide to us in your use of: (1) our website(s) (our “Sites”), (2) our application named Hyper-C as an Mobile game which can be played by End Users on a feature phone, smart phone, PDA, tablet computer, portable media player or other handled devices (“Mobile Devices”) and is operated in certain hardware environment with such operating system (“Markets”), includes, without limitation, Android, IOS and Windows phone (the “Application”), and (3) chat rooms, blogs, web forums, messaging boards or other public forums in Application and our Sites (collectively, our “Forums”). The Application, Sites and Forums are referred to herein collectively, as the “Services”. For the purpose of clarity, the Mobile game named Hyper-C is not HTML5 game which is is developed based on HTML5 language to enable you to play the Hyper-C on smartphone over the internet using a web browser as well as on computer over the internet using a web browser.
By accepting our Privacy Policy and the applicable Terms of Service during Service account registration or by otherwise accessing or using our Service(s) you are agreeing to the terms and conditions of this Privacy Policy (including our collection, storage, use and disclosure of your personal information) and that your access or use of the Service(s) is also subject to the applicable Terms of Service.
PLEASE NOTICE THAT COMPANY DO NOT PROVIDE ANY GAME SERVICE TO USER(S) IN THE TERRITORY OF EUROPEAN ECONOMIC AREA (EEA) WHICH INCLUDES THE EUROPEAN UNION MEMBER STATES AND ICELAND, LIECHTENSTEIN AND NORWAY AND THE UNITED KINGDOM (EUROPEAN USER). THEREFORE, PLEASE DO NOT ATTEMPT TO PLAY ANY GAME ON OR THROUGH ANY COMPANY’S SERVICES IF YOU ARE A EUROPEAN USER.
Collecting Personal Information
Our primary goal in collecting the information described below is to provide you, the user, EXCLUDING a European User, with a customized experience on our Service and to deliver better service, products, and more relevant content to our customers, prospective customers, and visitors.
1. Personal Information We Collect
Personal information may be collected from you during your use of the Service, including, during (a) the registration process, (b) promotional campaigns, (c) customer support and technical service requests, and/or (d) ordering and use of products and other services, or from and through third party service providers and partners. If you acquire the nationality, or any reason at all, by which you become an European User, you will notify such fact to Company for our terminating your access to the Services under the condition of relevant TERMS OF SERVICE and this Privacy Policy.
Information Collected Directly From You Registration Information. When you communicate directly with us, either through an Application, at our Site, a Forum, you are authorizing us to collect, store and use/share information collected from you in accordance with this Privacy Policy. Such information may include: (i) your age or birthday; (ii) your first and last name; (iii) your valid e-mail address and telephone number; (iv) I.D., password and other information necessary to ensure security of your account; and (v) such other information such as billing information, sex, profile photo, photo representation (avatar), character name, interests and hobbies, game play preferences, advertisement identifier, and Q&A information.
From time to time we may expand or change the information requested upon registration or log-in, so this may not be a complete list. We ask that you provide only your own personal information, not personal information concerning anyone else.
Usage Information. We collect details of your use of our Services and the resources that you access. Such usage information includes information about how and when you access or use our Services (such as Games accessed, game score, pages visited, purchase and use of Virtual Money and/or Virtual Goods, the details of your purchases, and your game play).
Interaction and Communications among Users. We collect information about (i) your interaction with other users (for example, invite, gift, sharing of your rank or level, screen-shots, etc.) and (ii) your communication and interaction with your contacts through social media channels (including, social network services, messengers, and any other services which has social features like invite friends and sharing information with friends).
Information through Mobile Devices. When you use an Application or Third Party Mobile Application on your mobile telephone or other mobile devices (“Mobile Device”), in addition to such information described above, you are authorizing us to collect, store and use/share the following information (as applicable): (i) Mobile Device type; (ii) mobile carrier; (iii) Internet Protocol address; (iv) geographic location/country; (v) platform version; (vi) navigation, interaction and engagement information regarding our users (vii) MAC address, International Mobile Equipment Identity (IMEI), display resolution, time and date on screen of Mobile Devices (viii) O.S. information, and; (ix) such other information you choose to provide to us. In addition, we receive and store information you provide when you sign up to have Short Message Service (“SMS”) notifications set directly to your Mobile Device.
Payment and Billing Information. If you purchase any in-Service items, our third party partners will collect the payment and billing information necessary to complete the transaction. Such information may include: (i) your first and last name; (ii) your valid e-mail address; (iii) credit card, PayPal and other third party payment processor information; (iv) billing address; and (v) such other information you choose to provide. Our third party partner may also receive the foregoing information that you provide when you purchase Application and Third Party Mobile Application through your Mobile Device.
Customer Service and Support. When you send email or other communications to us in connection with customer service and support, we will collect and store your contact information, information about your use of the Service, your user ID and such other information you provide to us in order to process your inquiries, respond to your requests and improve our Service. We will also store the correspondence and any information contained therein.
Profile Information. We provide areas on our Service where you can post information about yourself and others and communicate with others or upload content such as photographs. Such postings are governed by the applicable Terms of Service. In addition, such postings may appear on other websites or services, or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable areas, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control anyone who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.
Information Received from SNS and APIs
Because the Application is accesible through the Markets, you allow us to access certain information from your profile through the Markets’ Application Programming Interface (“API”). The information we receive varies by the Application and by the privacy settings for the Markets and may include any or all of the following information, as allowed by you, the Markets and your privacy preferences: (i) your first and last name; (ii) your profile picture or its URL; (iii) your user ID number; which is linked to publicly available information such as name and profile photo; (iv) the user ID numbers for your friends that are also connected to our Application(s); (v) login e-mail you provided to the Markets when you registered; (vi) your physical location and that of your access device(s) and (vii) your gender.
By using our Application(s) through an SNS, you are authorizing us to collect, store and use/share any and all information you agreed the SNS could disclose to us through the API in accordance with this Privacy Policy. Your agreement is evidenced when you “accept” or “allow” (or comparable terms) one of our Application on an SNS.
2. How We Collect Personal InformationAutomated Information Collection Technologies
As described below, when you access our Services, we collect certain technical information and may associate such information with your user or account ID number for our internal use.
Cookies
A “cookie” is a small text file that is sent to your browser from a web server and stored on your computer’s hard drive. We may use cookies to track general, non-personal information about our users (e.g., user name, pages viewed, time spent on our Site(s), games, and the sites visited just before and just after our Site(s)) for statistical and market research purposes.
We use cookies to gather information about our users’ browser activities in order to constantly improve our Service. This information assists us to design and arrange our web pages in a most user-friendly manner and to continually improve our Service to better meet the needs of our customers, prospective customers, and visitors.
We may also use local shared objects known as “flash cookies”, which help us to prevent fraud, remember your in-game settings and to track your progress on certain in-game tasks.
You have choices with respect to cookies. By modifying your browser preferences, you have the option to reject all cookies, or limit the type of cookies you allow. Flash cookies operate differently from browser cookies and cookie management tools available in a web browser will not remove flash cookies. To learn more about and manage flash cookies you can visit www.adobe.com. Rejecting or limiting the type of cookies may, however, in limited instances prevent you from accessing certain features on our Service.
Log Files
Like most Internet services, we may also use log files on the server side. The data held in log files includes your computer’s or Mobile Device’s IP (Internet Protocol) address, browser type, browser language, e-mail application, Internet service provider, referring/exit Web pages, computer platform type, date/time stamp, and user activity. The company uses server log data to analyze trends, administer the services offered through our Service. We and our third party partners may use this information for product and service improvements, and in marketing and advertising services.
The software enabling our Services has associated log and temporary files that are stored on Company’s servers. These files store your account information, preference settings, system notifications as well as other data necessary to enable you to participate in our Service. Your information may also exist within regularly performed server backups.
Tracking Technologies
Our Services may utilize a variety of methods for tracking purposes, including web beacons (also known as Internet tags, pixel tags and clear GIFs). Web beacons are small pieces of data that are embedded in images on the pages of websites to analyze the traffic patterns, such as the frequency users visit various areas of our Services. Pixel tags may allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation. These methods may involve transmitting information either directly to us or to another entity authorized by us to collect information on our behalf. We also use these technical methods in HTML e-mails that we send our guests to determine whether our guests have opened those e-mails or clicked on links in those e-mails. With web beacon technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address.
Third Party Advertisers
Many advertisements are managed and placed on the service by third parties. These third party advertisers may use cookies, web beacons or similar automated information collection technologies on your computer or Mobile Devices to help present, better target, and measure the effectiveness of their advertisements, by collecting non-personally identifiable information when you click on or move your cursor over one of their advertisements. We may share certain non-personally identifiable information about you as a user with certain third party advertisers to help them deliver more relevant advertisements through their ad networks. In some cases, we may have access to information from cookies, web beacons and similar automated information collection technologies used by third party advertisers on our Services and this information may permit us to identify other sites or services that you have visited that are also associated with the third party advertiser.
The use of cookies, web beacons, or similar automated information collection technologies by third party advertisers is subject to their own privacy policies. Finally, once you have clicked on an advertisement and have left the Service, our Privacy Policy no longer applies and you must read the privacy policy of the applicable third party advertiser to see how your personal information will be collected, stored and used as part of their service.
Click Through URLs
Some of our Services, including email messages, use “click-through URLs” linked to other content on our Services. We track this click-through data to help us determine interest in topics and use of the Services.
Monitoring/Public Information
You may also choose to disclose personal information in our Forums. Personal information you disclose in such Forums is public information, and there is no expectation of privacy or confidentiality. Please refer to the Terms of Service for additional information relating to the disclosure of personal information in such Forums.
Other Sources
We may collect or receive information from other sources including other users of the Service and third party information providers and partners. For example, we receive and store the information you provide when you enter any promotion, sweepstakes or loyalty program. Such information may be used to supplement your account information and/or profile and may be combined with other information we collect from you.
Use, Disclosure and Transfer
Unless otherwise described elsewhere in this Privacy Policy, we will not use or disclose any personal information collected from you. Your personal information may be used alone or in the aggregate with information collected from other users.
Use by Company
We use the information you provide so that we may better understand your needs and the needs of our customers, prospective customers, and visitors. Specifically, we use your personal information for many purposes, including:
(a) to allow you to register for and use our Services;
(b) to apply for employment opportunities at the Company;
(c) to audit and analyze data to improve and ensure the continued smooth operation of our Service;
(d) for market research purposes, including, without limitation, to analyze user characteristics and usage patterns in order to understand better how our Services are used and market them more effectively;
(e) to communicate with you concerning your account or to send you announcements, newsletters, promotional materials and other information about our Services or offerings of our business partners, and to offer you opportunities to participate in surveys, contest and sweepstakes;*
(f) to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving our Service;
(g) to respond to inquiries, troubleshoot problems, investigate incidents, and handle complaints;
(h) provide, maintain, protect and improve our Services, including keeping you posted on our latest Service announcements, software updates and upcoming events, and develop new services;
(i) protect our rights or property or that of our users;
(j) to satisfy any applicable law, regulation, legal process or enforceable government request;
(k) to send notices, such as communications about your purchases and changes to our Terms of Service, this Privacy Policy and other Service-specific policies, and to enforce applicable terms and conditions set forth in such policies;
(l) to enable user-to-user communications; and
(m) protect against harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.
The Company processes personal information on our databases, equipment and servers (owned by the Company and/or third parties in South Korea and in other countries). In some cases, we may process personal information outside of your country.
*If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or follow the process described in the “Opt-Out Provision” section below
Disclosure and Transfer to Third Parties
We generally do not disclose or transfer any personal information about our customers, prospects, or visitors to any third parties. We may however, disclose and transfer data which does not contain or reveal any personally identifiable information or is specifically attributable to you to our business partners, third party analytics service providers, ad networks and advertisers (collectively, “Partners”). Provided, however, some Partners may also act as third party service providers (described below) to us and may have access to your personally identifiable information. Moreover, Partners may obtain public information about you from your profile or other public sources.
We may also periodically engage in co-marketing activities, where we work with a complementary solution provider to launch a joint marketing program. In these situations, we will only send information to you on behalf of the other; we do not provide your personally identifiable information to such partner. We may also enter into business partnerships with other parties to provide specific services. If a user signs up for these services or responds to a particular marketing offer, we may share personally identifiable information such as your name or other contact information that is necessary for our business partner to provide these services or get in contact with you.
Disclosure of your personally identifiable information may occur when we engage or employ service providers, vendors or other third parties to facilitate the provision of our Services (including, without limitation, payment processing, data analysis, e-mail delivery, hosting services, customer service and promotional services) to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Such third party service provider (“Third Party Partner”) may have access to your personally identifiable information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Currently, the name of Third Party Partner, services performed by it on our behalf, service territory of it, and period of retention and use by it of Personal Information are as follows:
Name
Services
Service territory
period of retention and use of Personal Information
None
In the event Company combines with another company in the future through a corporate merger, sale, acquisition, liquidation or other similar process, your personally identifiable information may be transferred with the business or a part of it, or may be sold as an asset of the business, to the successor organization in such transaction. If material changes to the Company’s privacy practices will occur as a result of such transaction, we will notify you and other users in the manner described in this Privacy Policy.
In addition, upon the expiration or the termination of any third party license arrangements involving one or more parts of the Service, your personal information (including name, email address and other personally identifiable information) may be transferred to the subject third party licensor in accordance with the terms of the applicable license agreement. In advance of such transfer to a third party licensor, the Company will notify you and other users in writing in the manner described in this Privacy Policy.
Safety, Security and Legally Required Disclosures
Your personally identifiable information, and communications you make within the Service, may be accessed and disclosed if we believe that our Service is being used in the commission of a crime, when we believe in good faith that there is an emergency that poses a threat to the safety of you or another person and when necessary either to protect our rights or property including to enforce our Terms of Service, or for us to render the service you have requested.
We may also disclose personally identifiable information when required by law, regulation, court order, or in response to a subpoena or litigation discovery request, or in the good faith belief that such action is necessary in order to conform to the edicts of the law or comply with a legal process served on us. In addition, we will make any legally required disclosures to government authorities and provide notice to you of any breach of security, confidentiality or unauthorized release of personal or private data in accordance with applicable laws, rules and regulations.
Storage and Security
We employ reasonable measures (both online and offline) to protect the security of information we collect from you. Such information is housed in secure databases, equipment and servers located in the South Korea and/or in other countries. The databases, equipment and servers we utilize may be owned by third party providers. To prevent unauthorized access, loss, or misuse, maintain data accuracy, and ensure the appropriate use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we maintain. We use industry-standard technology, such as firewalls, in an effort to protect the confidentiality of your personal information. Moreover, in addition to password protection offered in connection with your Service account, we encrypt your transmission of sensitive information to us (e.g., account passwords and payment-related identifiable information) via SSL (secured socket layer) protocol in the interest of heightened privacy protection and information integrity.
Although we take reasonable precautions against possible security breaches of our Service, databases, equipment or servers, and records, we cannot guarantee that unauthorized access, hacking, data loss, or other security breaches and factors beyond our control will never take place and result in disclosure of your personal information. Accordingly, we disclaim any guarantees, warranties or representations relating to maintenance or nondisclosure of any personal information collected from you. We strongly urge you to take reasonable measures at all times (online and offline) to protect your personal information, including your password and other sensitive information.
In addition, while we strive to protect your personal information, you should know that information sent over the Internet, whether by e-mail or by using one of our on-line forms, is not necessarily secure against interception. Therefore, we cannot be responsible for such interception and cannot guarantee the security of such information.
We will investigate, attempt to resolve and take all reasonable steps necessary to ensure that your personal information and data is treated securely and in accordance with this Privacy Policy.
We will retain your personal information for as long as is necessary to fulfill the purposes for which it was collected or as needed to provide you with Services. We may retain your personal information after you have closed any account you have with us or after we have ceased providing Services to you if retention of your Personal Information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between members, prevent fraud, cheating or abuse, or enforce this Privacy Policy or any other agreement we may have with a user.
Additional Privacy Policy TermsOpt-Out Provision
When we first collect information from you, we will offer you the opportunity to opt-out of having your personal information shared with parties outside of Company (unless otherwise described in this Privacy Policy). In addition, if you do not want us to send you communications relating to our Services, including, without limitation, announcements, newsletters and promotional materials or offers to participate in surveys, contests or sweepstakes, you can opt-out at the time of registration or information collection. If, at a later date, you choose to have your name or any other personal information removed from our mailing list, you can do so by emailing ([email protected])
Review, Update, Correct, or Delete Personal Information
Generally, you may review, update, correct or delete your personal information collected by or through our Service by logging into your account. You may also correct factual inaccuracies. Certain types of personal information that is necessary to check eligibility, such as birth date or age, cannot be deleted, but may be modified with sufficient verification of the new information. Note that we reserve the right to terminate or delete any registration or promotional entry if we believe the personal information submitted was knowingly false or fraudulent.
To delete your personal information, you may also email us at ([email protected]). We will use commercially reasonable efforts to honor your request.
Please be aware that even after your account is terminated or deleted, some or all of your information may still remain visible to others, including but not limited to any information that has been: (i) incorporated into others user’s content, comments, postings, submissions, cities, resources or other in-game assets; (ii) copied, stored or disseminated by other users; (iii) shared or disseminated by you or others such as in a public posting; or (iv) posted on a third party platform. A request to delete and/or termination of your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us. We are not able and/or obligated to remove any of your information from a third party platform.
Moreover, please be aware that even after you delete your account or your account is terminated, your information is not deleted in its entirety from our servers and may not be deleted from servers of the third party platform you use to access our Services. We may, but are not obligated to, retain backup copies of your information, including personal information on our servers or databases (and/or any authorized third party servers or databases we use). Such information may be disclosed pursuant to this Privacy Policy regardless of whether your account is deleted or terminated. Moreover, any third party platform that you use to access the Services may also retain backup copies of your information even after your account is deleted or terminated which may be used and/or disclosed in accordance with their privacy policy.
To have access to your personal information, you must provide proof of identification such as full name, street address, city/state and zip code, user ID and password, and/or information about your recent activity on our Service. We reserve the right to deny access to any user if we believe there is a question about your identity. And if the burden or expense of providing access to your personal information is disproportionate to the risks to your privacy, or if the legitimate rights of others would be violated, we may decide not to provide access to such information. Moreover, we may still retain an archived copy of your information in our files as required by law or for legitimate business purposes, including, resolving disputes, enforcing the Terms of Service, and for other technical and legal requirements and constraints related to our Service.
To manage the information we receive about you from the SNS where you play our games, you will need to follow the instructions at that SNS for updating your information and changing your privacy settings.
Advertising
We use advertising in our Services so we can continue to offer many of our Services for free. When advertisers or ad networks place ads in our Services, they may collect the Advertising IDs types of information from within our Services:
Advertising IDs are used by ad networks for a number of purposes (please refer to the Privacy Policies of our advertising partners listed here) including, for example, to:
(a) limit the number of times You see the same ad
(b) ensure they are dealing with humans with real devices and not automated “bots”
(c) to serve You with advertisements likely to be relevant to You based on Your advertising ID, Your engagement with other brands and ads which is recorded using Your advertising ID, and to use Your general geographic area.
(d) Ad networks track which games You have used to market You similar kind of games.
Your IP address is typically used by advertisers to identify your general geographic location, for example, your country, state and, sometimes, your city.
The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology.
Our advertising partners may combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.
This Privacy Policy does not apply to the collection of your information by our advertising partners.
For the list of the advertisers are as followed.
Party Name
Function
Relevant Privacy Policy
Apple (GameCenter)
Leaderboards. Cloud save of user progress. Transaction handler.
