Game Privacy Policy 2027

1. Introduction
   Thermae Game Studio (hereinafter referred to as “we,” “our,” “the Company,” or “us”) collects, uses, and processes information about you (hereinafter referred to as “you,” “the user,” or “the player”) and provides various game-related services (e.g., games, websites, events, surveys, e-sports, or customer service) (hereinafter referred to as “Games and Services”). This Privacy Policy (hereinafter referred to as the “Policy”) explains the personal information provided, collected, or generated when you access, use, or subscribe to our Games and Services, except where other privacy policies or terms and conditions apply. This Policy applies to our Games and Services, and it also explains the rights and choices you have regarding such data, as well as how you may communicate with us. This Policy does not apply to, nor can it control, activities you engage in when clicking on or accessing other websites through our Games and Services.

We may update this Policy from time to time, and in such cases, the effective date stated above will be revised. We will inform you periodically of this Policy or any significant changes to it, and continued use of our Games and Services constitutes your acceptance of any amendments to this Policy. We encourage you to review this Policy regularly to remain informed about how we collect and process your personal information. From time to time, we may ask you to confirm your acceptance of this Policy when providing Games and Services.

2. Information We Collect
   We will collect the following categories of information that may directly or indirectly identify or describe you or your device, or that may reasonably relate or be associated with you or your device. The information you provide to us may vary depending on the circumstances. Such information includes, for example:

1) Identification information, such as PlatformID, nickname, name, IP address, email address, postal address, phone number, date of birth, gender, country/region of residence, language, nationality, and so on;

2) Device or network information, such as device model, operating system version, MAC address, device ID, etc.;

3) Game information, such as information regarding crash reports and detailed system activity (game settings, game date/time, etc.); and

4) Purchase information, such as purchase date and items.

When you use social features (e.g., in-game text/voice chat), such information you disclose is considered public information. We may store and access this information, and other users may read, copy, collect, or use it without your consent.

We use this data to operate and improve our Games and Services. Some of this information is collected through cookies and related online tools/technologies. Please refer to the “Cookies and Related Technologies” section below for more information.

3. How We Use Your Information
   We use the information we collect for various purposes, primarily to provide games and services to players (such as you) and to improve the quality of our games and services. These purposes include:

1) Operating and providing games and services;

2) Developing new games, improving the quality of games and services, and fixing bugs;

3) Detecting illegal or unauthorized use of our games and services and taking action against it;

4) Managing your inquiries and requests (for example, in-game refund items);

5) Providing promotional information and other information regarding marketing, promotional activities, and surveys;

6) Tracking usage patterns, analyzing user trends, and calculating statistics related to games and services;

7) Compiling user statistics and providing in-game metrics (e.g., leaderboards);

8) Complying with and enforcing legal requirements, agreements, and policies.

For voice chat features, to detect abnormal or unauthorized activities (such as cheating or illegal advertisements), temporary voice data may be processed locally on your device during the game session. This temporary voice data will be automatically deleted after the game session ends. However, if a violation is detected, the related detection records (which may include some related voice data) may be transmitted to our servers and retained for a limited time as described in this policy.

In most cases, we need to process your personal information in order to respond to you or handle your requests. We may also process your information to comply with applicable legal obligations. From time to time, we may use your information for specific purposes, for which we will seek your consent beforehand. If such consent is required and you have given your consent, you may contact us at the addresses provided in this policy to withdraw your consent at any time.

4. How We Share Your Information
   We may share some of your personal information with third parties in order to provide you with our games and services, including service providers who process your personal information on our behalf to provide you with our games and services (such as customer support and managing our community). Some examples of these third parties are provided below. However, we do not share your information with third parties for cross-context behavioral advertising.

1) Third-party program restriction providers for anti-cheat tools and unauthorized programs;

2) Cloud computing service providers that provide cloud storage services;

3) Payment service providers that assist with transaction payments or provide withdrawal services to sellers;

4) Marketing platform and analytics service providers that provide player behavior-related services for the purpose of customizing services and conducting marketing activities (e.g., leaderboards);

5) Online survey service providers involved in improving game services;

6) Customer service providers that manage user inquiries.

We may also share your information with our affiliates (list: https://krafton.com/en/studios/) in the event of mergers and acquisitions, or to comply with legal obligations or legitimate data access requests, or share your information when you otherwise consent or we exercise discretion as described in this policy.

5. Cookies and Related Technologies
   We use technologies like cookies to identify your browser or device, learn more about your interests, provide you with basic functions and services, and for other purposes. When you use our games and services, approved third parties may also set cookies and related technologies.

Cookies are small files downloaded to your device (if your browser allows cookies) used to track activity across the website and customize your experience on the website. Most internet browsers allow you to delete cookies from your device’s hard drive, block cookies, or receive alerts before storing cookies. You can refer to your browser’s instructions or the “Help” page for more information on how to manage cookies. Please note that if you block cookies, some parts of our website may not function properly.

We use third-party analytics services to improve our services and your experience. Analytics service providers may collect your activity data while you use our games and/or services. However, we do not allow the collection or access to information that can directly identify you, such as your name, email address, etc. You can find information below on how to manage the collection of your data.

• Google Analytics: https://tools.google.com/dlpage/gaoptout

In addition, we strive to provide all players with a safe and fair gaming environment. When you play games, we or third parties may use cookies and similar technologies, or collect data from your computer or device, for fraud prevention, security, and authentication purposes.

6. International Data Transfer
   We operate globally, and in order to provide our games and services, we may transfer your data to countries and regions outside of the country or region where you are located. If your personal information is transferred, stored, or processed by us, we will take reasonable measures to protect your personal information privacy, including, where appropriate, entering into confidentiality and standard contractual clauses with service providers. For additional information on the international transfer of your information, please refer to the relevant information available according to your region. Please see the following supplementary terms section for more information.
7. Retention and Deletion of Personal Information
   In principle, we will delete your personal information as soon as the purpose of collecting the personal information has been achieved. Personal information stored in physical form will be shredded or burned, and personal information stored electronically will be deleted using technical measures that make it impossible to recover the information. However, if it is reasonably necessary for us to retain your personal information in order to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, deception, or misuse, or fulfill the purposes of this Policy or any other agreement we may have with players, we may retain your personal information even if you have closed your account registered with us or we have stopped providing services to you.
8. Our Policy Regarding Children
   This game and/or service is not intended for use by minors. Therefore, we do not knowingly collect, use, or share any information about them. When handling information about children under the age of 14, we will seek the consent of their parents or guardians before collecting the child’s personal information prior to the child’s use of our games and services. If you are a parent or guardian and believe that your child has provided information to us, you can contact us to request the deletion of your child’s information from our system.
9. Links and Third-Party Services
   If you click on links to third-party websites (including but not limited to advertisements), you will leave our site and be redirected to a website of your choice. Since we cannot control the activities of third parties, we cannot guarantee that they will follow the same privacy and security practices as us. We encourage you to review the Privacy Policy of any other service provider from whom you request services. If you visit third-party websites linked to our games and services, you should review that site’s privacy policy before providing any personal information.
10. Your Information Security
    We have taken appropriate security measures, including encryption and de-identification, to protect your personal information. In addition, we only allow employees, agents, individuals, or companies who need to know or access your personal information for business purposes to access your personal information. They will only process your personal information according to our instructions and fulfill confidentiality obligations where appropriate. However, please note that data transmission over the Internet cannot be guaranteed to be absolutely secure, so there are also risks involved in collecting and using information. Our information protection activities are audited annually by external organizations according to the Korean information security standard ISMS-P (Personal Information and Information Security Management System).
11. Your Privacy Rights
    Under the restrictive provisions of applicable law, you have the right to object to or request restrictions on the processing of your personal information, and the right to access, correct, delete, and transfer your personal information. To make a request regarding your rights, or if you have any other questions, please contact us by sending an email to the address stated in Section “13. Contact Us.” We will respond to all requests made by individuals wishing to exercise their data protection rights under applicable data protection laws.
12. Modifications
    We may, at our discretion, modify any part of this policy at any time by posting or displaying the revised policy in the game and services. In the case of significant changes, we will post a prominent notice on our website or in the game and services, or otherwise provide you with reasonable notice before any significant change takes effect. All other changes take effect upon posting.
13. Contact Us
    If you have any questions about this policy or your interactions with our games and services, please contact us by sending an email to sbai@qq.com.