Privacy Policy
(Last updated on 23TH November 2023)
1 About This Privacy Policy
This Privacy Policy pertains to the privacy practices of Zempot Inc. and its affiliated companies (hereinafter referred to as "Zempot" or "the Company"). Terms not defined in this Privacy Policy have the same meanings as those defined in the Terms of Service.
We respect your personal information ("User" or "You") and make every effort to protect it. This Privacy Policy explains the types of information we may collect, how we collect, use, and disclose such information when you access or use our games, websites, applications, or other services (collectively referred to as "Services").
By accessing, downloading, registering, or using our Services, you agree to this Privacy Policy. If you do not agree with the contents of this Privacy Policy, please do not use our Services.
We may update this Privacy Policy from time to time ("Changes to Privacy Policy" section). Please regularly review this policy to check for updates. Your continued use of our Services after we make changes is deemed to be an acceptance of those changes.
2 Information We Collect
We collect various information about users of our Services, including (1) personally identifiable information (e.g., name, address, email address, phone number) or other identifiers that can contact you, (2) information about you that is not individually identifiable, and (3) details about your internet connection, the devices, programs, or systems used to access our Services, and usage details.
2.1 Information You Provide Personal information you provide to us is collected directly from you. For example, when you (1) register an account with us, (2) sign up for our services or subscribe to newsletters and emails, (3) make purchases, (4) post your content or use social features in our services, (5) participate in contests, promotions, or events sponsored by us, or (6) respond to our surveys.
Information we collect may include:
Nickname, country, email address, player ID
Social media account ID or channel ID
User profile information, including other information you may provide for your profile photo and profile
Details of transactions you carry out through our Services, including payment information
Responses to surveys we may request from you
Communications between you and others through our Services
Content or information you post, publish, or display in public areas of our websites or applications
2.2 Information Provided by Third Parties We may receive information about you from third-party partners and companies. This can happen when you (1) purchase or download our games or other products from third-party stores such as Google Play, (2) register and log in to Zempot games using third-party social media accounts (e.g., Facebook, Google, Apple), or (3) receive information about you from third-party partners and companies.
Information received from these third-party partners and companies may include:
Your name, photo
Device identifiers
Account numbers, IDs, and usernames associated with the use of third-party stores, social media, or platforms
Country information, email address
Additionally, to enhance your gaming experience and provide personalized content (including ads), we may integrate data received from third parties with the personal information we collect and maintain.
2.3 Automatically Collected Information When you access, use, or interact with our Services (including websites and applications), we may use data collection technologies to automatically gather specific information about you, your device, and your usage of the services.
Information we automatically collect may include:
Your IP address
Your country information
Unique identifiers assigned to you or your device, including player ID and advertising ID
Details of your access to and use of our websites, applications, and other services, including specific games accessed, game progress, scores, purchased games and products, pages visited, and interactions with online content (including ads)
Geographical location (e.g., approximate location derived from IP address or metadata in photos or files you upload or share)
The information automatically collected may include personal information, and we may associate or integrate it with other personal information collected through other means, such as information received from third parties. This helps us improve our services and provide a better, personalized experience.
2.4 Cookies and Tracking Technologies Cookies are small files stored on a user's computer or mobile device. We, as well as third-party partners such as analytics providers, advertising networks, and other advertising service providers, use cookies and similar tracking technologies to collect information, understand service usage patterns, and personalize user experiences.
We use cookies for various purposes, including:
Security and service integrity cookies: We use security-based cookies to ensure service security. We can use information obtained from security and service integrity cookies to detect and protect against fraudulent or abusive activities, protect user safety, and enforce our terms of service and other user agreements. These cookies are essential, and you cannot block them if you want to use our services.
Performance and functionality cookies: We use analytics and research cookies to collect information about the scale of visitors, usage patterns, and types of devices used. We can use this information to create aggregated statistical reports and support service improvements. Additionally, we use functionality tracking cookies to collect information about how our services perform. We may use this information to create reports and improve services.
Advertising cookies: We use advertising cookies to personalize ads displayed to you in our services and on third-party websites and services. When you use our services, third-party partners and companies may use these cookies to personalize advertising content.
You can refuse to accept cookies by enabling appropriate settings on your browser or smartphone. However, choosing these settings may mean you cannot access certain parts of our services (refer to the "Your Choices About How We Collect, Use, and Disclose Your Information" section for more details).
3 How We Use Your Information
We use the information collected about you, including your personal information, for the operation of our business, service improvement, and personalization of your experience. Additionally, we may use this information for other purposes permitted by law. For example, we (or third parties acting on our behalf) may collect, process, and use your information for the following purposes:
Provide our services to you, including games and other services, and personalize your gaming experience.
Fulfill your orders, including purchases of our products or services, and other purposes for which you provide your information.
Set up and manage accounts registered with us, and maintain transaction records.
Store game data and enable gameplay across multiple devices.
Activate game matches for competitive gaming and display game leaderboards and player game statistics.
Facilitate social interactions among users and help users find friends online.
Host forums or boards related to our games or services.
Conduct surveys about our products and services to better understand customers and provide services.
Organize game events, contests, prize draws, and promotions.
Provide technical support for your account, purchases, subscriptions, or services upon request.
Send you offers, promotions, newsletters, and communications related to our services or products, as well as third-party products and services.
Display relevant ads tailored to your interests and preferences on various sites and apps, including our services, and measure and analyze the effectiveness of advertisements.
Conduct research and analysis to develop and improve our services.
Monitor and track the operation of our services, including websites, applications, and networks, and track purchase and usage information.
Detect and prevent fraud, malicious, or illegal activities.
Investigate user complaints, disputes, monitor chats, and/or regulate player online behavior.
Fulfill obligations arising from any contracts entered into between you and us, including claims and collections.
Enforce legal terms applicable to your use of our services.
For any other purpose that we, in our sole discretion, determine to be necessary or required, including but not limited to ensuring the safety or integrity of our users, employees, third parties, or our services, and compliance with applicable legal requirements.
We retain your information. Generally, we keep your personal information for the time necessary to achieve the purposes for which we obtained it and as necessary to provide our services. If you close your account with us or cease to use our services, we may retain your personal information if reasonably necessary for legal compliance, dispute resolution, and other legitimate business reasons. We may also aggregate or anonymize the information collected, and, in accordance with applicable law, use or share anonymized or aggregated information.
4 Entities with Whom Your Information May Be Shared
We may disclose aggregated information and information that does not identify individual or device without restriction. Additionally, we may disclose the personal information we collect or you provide as described in this Privacy Policy.
Our Affiliates and Subsidiaries: We may share your information with our affiliates for the purposes described in this Privacy Policy.
Contractors and Service Providers: We may share your personal information with contractors, service providers, and other third parties we engage to support our business. We share your information with them for purposes described in this Privacy Policy and to provide services to you or perform actions reasonably necessary to provide our services (refer to the "How We Use Your Information" section).
Advertising Partners: Our services may include tracking tools of third-party advertising partners that collect information about you and your use of our services for purposes of serving targeted ads to you. These third-party advertising partners may use the data (and similar information collected on other websites) for the purpose of delivering targeted advertising. These companies operate under their own privacy policies, which may differ from our policies. Refer to the "Third-Party Sites and Services Collecting Information" section for more details.
Other Business Partners: We may share your information with third-party app stores, game platforms, and other business partners who provide services related to our services.
Third-Party Plugins: Social media features and tools integrated into our services (e.g., Facebook "Like" button or "Share" button) are hosted by third parties. These third-party features and tools may collect information when you use our services. Their use of the information is governed by the privacy policies of the providing third party.
Social Features: When you use social features in our services, such as sharing your username (ID) and profile publicly, your information may be shared with recipients or the general public. For example, all information included in a public profile can be viewed by others. Additionally, content you post or display in public areas of our services, such as player forums or boards, may be visible to others.
User Content: You agree that your user content, posted or transmitted through our services (collectively referred to as "User Content"), is your responsibility to share with others. We cannot control the actions of other users or third parties with whom you choose to share your User Content. Therefore, we do not guarantee and are not responsible for unauthorized access to your User Content by unauthorized persons or entities.
Business Transfers: In the event of a merger, acquisition, dissolution (including bankruptcy), change of control, or the sale of all or part of our assets, including customer information, personal identification information is usually one of the business assets transferred. If such a transaction occurs, the successor may continue to use your personal information as outlined in this Privacy Policy.
With Consent: With your explicit consent, we may share your information with third parties for additional purposes. You agree that we may share your information with third-party recipients who may use your information in accordance with their privacy policies.
Compliance with Law: We may also disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with legal obligations (e.g., court orders or subpoenas), (ii) enforce terms and policies, and/or (iii) protect our rights, property, or safety of us, users, or others. We fully cooperate with law enforcement agencies in identifying individuals using our services for illegal activities. We reserve the right to report any activities that we, in good faith, believe to be illegal to law enforcement agencies.
Please note that the sharing of information as described in this section may involve the transfer of your information to other countries that may have different data protection rules than your country.
5 Third-Party Sites and Service Collecting Information
Our services may include links to third-party services. These third parties may have their own privacy policies and data-related practices that may differ from ours. We do not control or take responsibility for the privacy policies or data-related practices of these third-party sites or services. Before using each third-party site or service, you should review their privacy policies.
Additionally, when you use our services, certain third parties, such as advertisers, ad networks, ad servers, and analytics companies, may use automatic information collection technologies to collect information about you or your device. These third parties may use cookies and other tracking technologies to collect information about you when you use our services or view ads or click on them. The information they collect may be associated with your personal information and may collect information about your online activities over time across various websites, apps, and other online services. Websites may use this information to provide interest-based (behavioral) advertising or other targeted content.
We do not control these third parties' tracking technologies or their use. If you have questions about ads or other targeted content, you should contact the responsible provider directly. Third-party providers that may collect personal information within our services are listed in the table below.
Our advertising services and analytics providers include the following companies:
|
Third-party Name |
Privacy Policy |
|
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Firebase |
|
|
|
|
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AdMob |
|
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IronSource |
https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/ |
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Singular |
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ZENDESK |
|
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Xsolla (USA), Inc |
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LY Corporation |
6 Your Choices Regarding the Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the collection and use of your personal information. Specific options available may vary depending on the service you are using.
Promotional Messages from Us: If you do not want us to use your contact information for marketing purposes, you can request to opt-out by sending an email to privacy-help@zempot.com
You can also unsubscribe from marketing communications by clicking on the unsubscribe link provided in the email.
Tracking Technologies: You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. Disabling or rejecting cookies or other tracking technologies may limit your access to certain parts of the service, and some features may not function properly.
Targeted Advertising: If you do not want us to use the information you have provided to deliver advertisements based on your preferences or those of advertisers, you can take one of the following actions to opt-out:
6.1 Website: Adjust your browser settings to limit specific online tracking.
Chrome
Edge
Safari
6.2 Mobile Application: Enable "Opt out of Interest-Based Ads" (Android) or "Limit Ad Tracking" (iOS) settings on your mobile device and reset your ad identifier.
Android Chrome
iOS Safari
Residents of specific states or countries may have additional privacy rights and choices. For more details, refer to the "Your Privacy Rights" section provided in this Privacy Policy and any other notices specific to your state or country.
7 Methods to Safeguard Your Information
The security of your personal information is important to us. We maintain appropriate technical and physical safeguards to protect your personal information from unauthorized access, loss, and misuse. While we take measures to prevent unauthorized exposure or access to your information, no security measures are perfect. Therefore, we cannot guarantee the security of your information. By using our services, you agree to accept the risks associated with the unauthorized use or access to your information that is beyond our control. We do not assume any responsibility for unauthorized use or access to your information.
8 Protection of Children's Personal Information
The terms "child" or "children" as used in this agreement refer to individuals under the age of 13 (or any other age as required by law), and the term "parent" includes legal guardians. Our services are intended for general users, and certain game features and services are only provided to players who are at least 18 years old. We do not knowingly collect, use, or share any personal information from children without verifiable parental consent or as permitted by law. If you believe that we have inadvertently collected personal information from a child, and you are the parent, you can contact us at privacy-help@zempot.com or visit our customer center page to request the removal of your child's information from our systems.
9 Your Privacy Rights
Consumer privacy laws may provide residents with additional rights regarding their personal information. Depending on the area where you reside, you may have the following rights:
Access Rights to Personal Information/Data Portability: You may request access to the categories and sources of information we have collected about you, the business purposes for which we use or share your information, and the users with whom we share your personal information, up to two times in a 12-month period. You may also request that we provide your personal information in a commonly used and machine-readable format (data portability request). Certain exemptions may apply as per the law.
Right to Delete Specific Personal Information: You may request the deletion of your specific personal information, subject to certain exceptions allowed by law. For example, we may deny your deletion request if we need to retain your information to provide you with requested services, protect against fraud or illegal activity, or comply with legal obligations.
Right to Correct Inaccuracies: You may request that we correct any inaccurate or incomplete information we have about you.
Right to Restrict Processing: You may request to restrict the processing of your data in certain circumstances, such as disputing the accuracy of your data, when the processing is unlawful, or when we no longer need the information for the purposes of processing.
Right to Object to Processing: You have the right to object to the processing of your personal data for direct marketing purposes or if the processing is based on our legitimate interests or for the performance of a task carried out in the public interest, or in the exercise of official authority.
Right to Opt-Out of Automated Decision-Making, Including Profiling: Residents in certain states have the right to opt-out of the processing of personal data for targeted advertising and sales. While we do not engage in "profiling" as described by the law, you can follow the steps described in Section 6 of this Privacy Policy to exclude yourself from targeted advertising.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights. Unless permitted by law, we will not deny you goods or services, charge you different prices or rates, or provide you with a different level or quality of goods or services for exercising these rights. However, we may provide certain financial incentives that are permitted by applicable law, and which may result in different prices, rates, or quality levels.
To exercise these rights, you can use the contact details provided in the "Contact Information" section below. To make an access or deletion request, we need sufficient information to reasonably verify your identity. You do not need to create an account with us to make these requests. However, if you have an account with us, we may consider your password-protected account to be sufficiently verified. If you do not have an account with us, we may ask for unique details about you and your device to verify you.
Only a parent or legal guardian can exercise privacy rights on behalf of a child. If a designated representative is submitting a request on your behalf, we may require proof of valid delegation under the laws of your place of residence.
10 California Residents Privacy Notice
This California Resident Privacy Policy supplements our Privacy Policy and applies solely to all visitors and users from California.
10.1 Notice of Collection
We collect your personal and sensitive personal information to support our business operations, including the business purposes described in the "How We Use Your Information" section.
Depending on how consumers use our services, we may collect the following categories of personal information from California consumers:
Identifiers such as nicknames, email addresses, IP addresses, social media account or channel IDs, store account numbers, player IDs, and device identifiers.
Customer records including nicknames, payment information, billing, customer communications, and other records between the customer and us.
Commercial information including purchase, acquisition, or consideration of games and products, and other transaction records such as orders, payments, and deals.
Internet or network activity information including details about users' access and use of our services, such as accessed games, game progress and scores, visited pages, and user interactions with online content.
Geographical location data derived from IP addresses or country codes.
Technical data about users' devices, software, and systems.
User profile information including country, profile pictures, and other information users may provide.
Content and information that users post or display on the website or application.
User messages and chat content within our services.
Survey responses, including answers to surveys and other information derived from other personal information.
If you are a California resident, we do not sell or share your personal information for targeted advertising purposes. Generally, we retain your personal information for the duration necessary to achieve the purposes for which it was collected and to provide the services, even after you close your account or after we discontinue providing services to you, if reasonably necessary for our legitimate business purposes or legal reasons.
For additional details, please review our full Privacy Policy.
10.2 Additional Information for California Residents
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Category of Personal Information |
Categories of Third-Party Recipients |
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Identifiers |
Our subsidiaries and affiliates, service providers such as customer support, IT, and cybersecurity providers. |
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Customer records |
Our subsidiaries and affiliates, payment processors, customer support, and IT providers, other business partners such as third-party app stores and game platforms. |
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Account details |
Our subsidiaries and affiliates. Our subsidiaries and affiliates, other business partners such as third-party app stores and game platforms. |
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Commercial information |
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Internet or network activity |
Our subsidiaries and affiliates, service providers such as customer support, IT, and cybersecurity providers. |
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Geographical location data |
Service providers. |
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Technical data about users' devices, software, and systems |
Our subsidiaries and affiliates. |
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User profile information |
All users with access to our services. |
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User-posted content |
All users with access to our services. |
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User messages and chat content |
Service providers (e.g., customer support providers). |
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Survey responses |
Service providers (e.g., customer support providers). |
For detailed explanations of the categories of information mentioned above, please refer to Section 10.A.
The California Consumer Privacy Act ("CCPA") provides specific rights to California residents regarding their personal information. These rights include the right to access personal information, the right to delete specific personal information, the right to correct inaccurate personal information, and the right not to be discriminated against for exercising CCPA rights. To understand how to exercise these rights, refer to the "Your Privacy Rights" section.
10.3 Privacy Rights of California Minors
California residents under 18 have the right to request the deletion of content or information posted anywhere on our services, such as public forums or bulletin boards. Requests can be made by contacting privacy-help@zempot.com
Removal of your information or content may not be complete or comprehensive, and residual copies of removed information or content may remain on our servers. Additionally, we are not obligated to delete content or information posted, copied, or reposted by third parties, anonymized information, or information that must be retained under the law.
10.4 Other California Rights
The California "Shine the Light" law (Civil Code Section 1798.83) allows California residents to request certain information about our disclosure of personal information to third parties for direct marketing purposes. To make such requests, email privacy-help@zempot.com
If you have questions about this notice, please contact us using the contact information provided in the "How to Contact Us" section.
11 Additional Information for Nevada Residents
Nevada residents have limited rights to opt-out of the sale of their personal information. Nevada residents wishing to exercise this right can send an email to privacy-help@zempot.com to submit their opt-out requests. However, we do not currently sell data that triggers opt-out requests under this legislation.
12 Additional Information for EEA and UK Residents
Legal Basis for Processing Your Personal Information
If you reside in the European Economic Area (EEA) or the UK (or a country with similar legal requirements), we will only process your personal information when we have one or more legal bases, including:
12.1 Your consent for the processing of personal information.
12.2 The need to perform a contract with you or to take steps at your request before entering into a contract, such as providing services and features you request.
12.3 Compliance with a legal obligation, including court orders, subpoenas, and other applicable laws.
12.4 Protection of vital interests, such as preventing and responding to fraud, misuse, or other illegal activities that could harm users or other individuals.
12.5 Processing necessary for our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. For example:
Customer service and technical support.
Providing advertisements based on your preferences.
Detecting and resolving bugs, security, or technical issues.
General Data Protection Regulation (GDPR) Rights
If you reside in the EEA or the UK, you have rights regarding your personal information under the GDPR. You have the right to access, modify, and delete your personal information or object to the processing of your personal information in certain circumstances. You also have the right to request that we transmit your personal information to another data controller. If you have given consent for the collection, processing, and transfer of your personal data, you have the right to withdraw your consent.
To exercise these rights or withdraw consent, contact us using the contact details provided in the "How to Contact Us" section. All communications must be in writing.
If you have questions, concerns, or wish to make access or other requests, you can contact us at any time. If your concerns are not resolved, you have the right to lodge a complaint with the data protection authority in your local jurisdiction.
13 Location of Your Information
Your personal information may be transferred and stored in countries, including South Korea, that have data centers operated by us or our affiliates. It may be processed by employees of our affiliates and third-party service providers, and these employees may operate outside your country or jurisdiction. In such cases, we will take commercially reasonable security measures to require the third parties to protect your information. However, data and privacy laws in other countries may not be as comprehensive as those in your residence country.
By using our services, you agree that your personal information may be transferred, transmitted, stored, and processed by recipients in other countries, and servers located in other countries, including through the Microsoft Azure network, for the smooth operation and provision of our gaming services.
If necessary, personal information may be transferred from the EEA and the UK to other countries using standard contractual clauses approved by the European Commission.
14 Changes to the Privacy Policy
Over time, we may update this Privacy Policy to clarify our practices or to reflect new or different privacy practices, such as when we add new features. We reserve the right to modify or change this Privacy Policy at any time.
If we make significant changes, we will provide notice on our website or through other appropriate means, as required by applicable laws. Changes to this Privacy Policy will take effect immediately upon posting on our website, unless we specify otherwise in writing. As we may update the Privacy Policy, please review it periodically. We will indicate the "Last Modified" date at the top of the policy with each update. If you continue to use our services through our website or third-party platforms after the effective date of policy updates, it will be considered that you have consented to and accepted the revised Privacy Policy.
15 How to Contact Us
If you have any questions about this Privacy Policy or our privacy practices, you can contact us using one of the following methods:
Address: 7th Floor A, Saemicolon Munrae N-dong, 25 Munrae-ro 28-gil, Yeongdeungpo-gu, Seoul, South Korea
Phone: +82-1670-4248
Email: privacy-help@zempot.com