Privacy Policy

Last Revised: Mar 16, 2023

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING ANY WEBSITE, SERVICE, GAME OR APPLICATION OFFERED BY XOGAMES, INC. ("XOGAMES PRODUCTS"), YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS DESCRIBED HEREIN AND ON OUR TERMS OF USE (https://sites.google.com/xogames.co.kr/tos/ko) AND ANY TERMS AND AGREEMENTS INCORPORATED BY REFERENCE. IF YOU DO NOT AGREE TO ALL OF THESE TERMS, DO NOT ACCESS OR USE ANY XOGAMES PRODUCTS.

SCOPE OF THIS POLICY; CHANGES
PERSONAL INFORMATION WE COLLECT
USES OF PERSONAL INFORMATION
SHARING OF PERSONAL INFORMATION
ONLINE COMMUNITIES
USE OF COOKIES, IP ADDRESSES AND WEB BEACONS
THIRD PARTY ADVERTISING COMPANIES
PROTECTING PERSONAL INFORMATION
OPTING OUT
SPECIAL NOTICE REGARDING CHILDREN
LINKS TO OTHER WEB SITES OR APPLICATIONS
CONTACT INFORMATION TO CORRECT AND UPDATE PERSONAL INFORMATION OR OBTAIN ADDITIONAL INFORMATION
CALIFORNIA RESIDENTS: CALIFORNIA CONSUMER PRIVACY ACT DISCLOSURE
P3P

1. SCOPE OF THIS POLICY; CHANGES

This privacy policy ("Policy") explains how personal information is collected, used and disclosed by XOGAMES Inc. ("XOGAMES", "we" or "us") with respect to your use of the XOGAMES Products.

We may revise and update this Policy at any time. We will alert you that changes have been made by indicating on this Policy the date it was last updated. If the changes are significant, we also will notify you on the XOGAMES Products that our Policy has been revised. We encourage you to review this Policy whenever you visit any of the XOGAMES Products to make sure that you understand how any personal information you provide will be used.

This Policy applies to personal information collected through your interaction with or use of the XOGAMES Products. This Policy does not apply to sites or applications operated by any third parties. In addition, this Policy is designed to apply to the XOGAMES Products operated in offices within Republic of Korea and not any international affiliates or other companies or organizations to which we link.

2. PERSONAL INFORMATION WE COLLECT

We may collect various types of information about you, including personal, demographic and aggregate data.

Demographic information is anonymous information, which may include your age, date of birth, gender, demographic area, hobbies or interests. Demographic information is not considered personal information unless it is linked with your other personal information, which we may do for a variety of reasons such as to customize the content according to your interests and preferences. Personal information does not include aggregate information, which is data we collect about the use of the XOGAMES Products or categories of such users, from which personal information has been removed. Aggregate data is used for a number of purposes such as to help us understand trends and user needs so that we can improve our products and services.

Personal information may be collected in a number of ways through the XOGAMES Products, such as when you voluntarily provide it in connection with registering, creating a profile, posting content, sending an email or message to another user or participating in the interactive games, forums or features of the XOGAMES Products. If you leave a comment on a forum or provide a testimonial on the XOGAMES Products, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit on or in the XOGAMES Products.

From time to time we may collect personal information that you provide in connection with your participation in surveys, sweepstakes, contests, games, promotional offers, and other activities on the XOGAMES Products. If we collect information from you offline and it is linked with personal information, we will treat that information as personal information. Some personal information may also be automatically collected through the use of the XOGAMES Products, as is described below (See Use of Cookies, IP Addresses and Web Beacons).

When you use a XOGAMES Product on your social network page or on someone else’s page, we may record information regarding the use of that XOGAMES Product, and we may collect other information that is visible on your social network page in accordance with the relevant terms of use associated with that page.

It is your responsibility to read and accept social networking sites’ Terms of Use, as well as their Privacy Policy prior to continuing to use such sites.

When you invite new members into your network or send messages through the XOGAMES Products, we collect and maintain the information associated with those messages, included email address and content.

3. USES OF PERSONAL INFORMATION

In general, we use personal information that we collect to process your requests or transactions, to provide you with information or services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to facilitate your use and our administration and operation of the XOGAMES Products, to learn more about and improve the XOGAMES Products and for the purpose for which information was provided. For example, we may use the information we collect:

i. To send you a welcoming email or contact you about your use of the XOGAMES Products, such as for administrative purposes or to provide you with customer service;

ii. To provide you with the services, products or information you request and to complete any transactions or facilitate the use of any features in connection there with, such as matching users for gameplay;

iii. To contact you about or to advertise our or a third party's services, products, activities, special events or offers and for other marketing, informational, product development and promotional purposes;

iv. To respond to your emails, submissions, comments, requests or complaints;

v. To notify contest winners; and

vi. To request feedback and to enable us to develop, customize and improve the XOGAMES Products and new offerings.

In addition, when you use one of our XOGAMES Products on a social networking site, we may record information regarding the use of that XOGAMES Product, and we may collect other information that is visible on your social networking site in accordance with the relevant terms of use associated with that page. This information may include, but is not limited to, your name, profile picture, the pictures of your social networking site "friends," gender, and game scores. We may retain this information to enhance your experience when playing our games. For example we may post the high scores and profile pictures of you and your friends while you play one of our XOGAMES Products.

4. SHARING OF PERSONAL INFORMATION

XOGAMES does not sell or rent personal information to third parties or share personal information with third parties outside the affiliated organization except as described in this Policy as it may be revised from time to time, or with your consent. We may share your personal information with organizations that are affiliated, which may use such information consistent with this Policy (see Use of Personal Information, above). We may also share personal information with consultants, vendors and service providers ("Service Providers") who perform functions on our behalf, but we require that Service Providers only use such information as is necessary to carry out their work. We also allow third party vendors to serve creatives and other ads on our sites to collect information about users' interactions with those ads. In addition, we may share your information with third parties if we have a good faith belief that the disclosure is necessary or appropriate to comply with law or legal process; to protect and defend the rights and property or personal safety of XOGAMES, our customers or the public; to prevent and protect XOGAMES and our users from fraudulent, abusive, unlawful or unauthorized use of the XOGAMES Products; or to otherwise enforce our rights and agreements. We also may share such information with official law enforcement authorities in our sole discretion. Your personal information also may be disclosed or transferred as part of, or during negotiations of, any merger, sale of company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of XOGAMES.

5. ONLINE COMMUNITIES

The XOGAMES Products may include certain online communities and other interactive features, such as user profiles, user gameplay matching, blogs, forums, message boards and chat rooms. You should note that certain information you post or provide to such public areas of the XOGAMES Products are publicly available and may be shared with other users. You can restrict user access to certain information through the privacy preferences setting on your account. However, although we strive to use commercially reasonable efforts to implement these privacy preferences, no system or security measure is perfect or impenetrable. In addition, when you use the XOGAMES Products you are interacting with other users, not just your designated friends. You should always be cautious when giving out personal information to others in public online forums. We strongly encourage parents to supervise their children’s activity in public forums and to caution them not to share any personal information.

6. USE OF COOKIES, IP ADDRESSES AND WEB BEACONS

When you visit the XOGAMES Products, we automatically collect certain information, such as your computer’s Internet Protocol (IP) address, your computer’s operating system, the browser type, the address of the referring Web site, and your activity on the XOGAMES Products. We may also collect certain information through the use of cookies. Cookies are small text files that are stored on your hard drive and record your preference and other data about your visit to the XOGAMES Products.

If we combine cookies with or link them to any of the personally identifying information, we will treat this information as personally identifiable information; otherwise it is treated as and used in the aggregate. You may block, erase, or be warned of cookies through the browser settings on your computer; however, if a browser is set not to accept cookies or if a user rejects a cookie, you may not be able to sign in or access XOGAMES Products or certain features of XOGAMES Products.

"Web beacons" (also known as "Web bugs," "action tags," "pixel trackers," or "clear GIFs") may also be used on the XOGAMES Products or in emails relating to the XOGAMES Products. Web beacons are small graphic images placed on a Web page or social network service application, Web-based document, or in an email message that allow the collection of certain information and monitor user activity on the XOGAMES Products. Web beacons are invisible because of their size (only 1 by 1 pixel) and because they are the same color as the background of the Web page or application. Web beacons are used to collect non–personal information such as the IP address of the computer that the Web beacon is sent to, the URL of the page the Web user comes from and the time the Web beacon is activated (such as when you view the Web page, application, advertisement, or email that contains the Web beacon).

We may also use one or more web analytics services. Web analytics services may record mouse clicks, mouse movements, scrolling activity as well as any text you type on any XOGAMES Product. We may use the information collected through web analytics services to improve the user experience on XOGAMES Products.

7. THIRD PARTY ADVERTISING COMPANIES

We may use or allow a third party advertising company or network to display ads on the XOGAMES Products or in XOGAMES Products. We may also use or allow a third party payment provider to collect information needed to facilitate payments and purchases on our site. Any information gathered by third parties is collected by such third parties, not XOGAMES. Such collection is handled by the third parties and therefore their privacy policies apply. For example, if you purchase goods or services from XOGAMES using the third party wallet provided by our payment processor or another vendor, including without limitation the Facebook credits program, your information may be stored by that third party for use with other participating sites or applications and would be subject to that processor’s or vendor’s privacy policy and practices.

Third–party companies who serve ads and/or collect certain anonymous information when you visit XOGAMES Products may also use non–personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to XOGAMES Products in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or third party web beacon to collect this information. To learn more about this behavioral advertising practice, or to opt–out of this type of advertising for companies that participate in the Network Advertising Initiative compliance program, you can visit www.networkadvertising.org.

Also, if an advertiser asks us to show an advertisement to users with certain characteristics (for example, women ages 18–24) or a segment of that group (for example, women ages 18–24 who have viewed certain categories of content) and you respond to that advertisement, the third–party advertising company may conclude that you have the characteristics of the audience they are trying to reach.

Also, note that with respect to XOGAMES Products, our system and the third–party advertising technology uses information derived from cookies on your drive and the XOGAMES Products you use to target advertising within our XOGAMES Products. In the course of advertisements being served to you, a unique third–party cookie or cookies may be placed on your computer.

From time to time, XOGAMES may use various third party vendors – such as, for example, Apple, Google, Facebook or their successors — for transaction processing, virtual goods sales, offers and similar purposes. Your interactions with third party vendors are also governed by their Terms of Use/Service/Sale and Privacy Policies.

Below are some of the links to various third party vendor terms and conditions (note that XOGAMES is not responsible for updating these links):

Google https://policies.google.com/privacy

Firebase https://firebase.google.com/support/privacy

Adjust https://www.adjust.com/terms/privacy-policy/

8. PROTECTING PERSONAL INFORMATION

We strive to protect personal information while it is under our control. Your account information is accessible online only through the use of a password. To help protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the XOGAMES Products by any person using your password. Please advise us immediately if you believe your password has been compromised or misused.

9. OPTING OUT

If you do not wish to receive promotional email from XOGAMES about our products and services, you may opt out at the time of registration or information collection. When implemented on the XOGAMES Products, if you wish to change your contact preferences at a later date, you may login in to the XOGAMES Products online and update your contact preferences. When implemented on the XOGAMES Products, you will have the ability to choose whether or not to allow other users to contact you through private messaging or email. Please note, even if you opt out of receiving promotional email from XOGAMES, you may still receive operational emails, including messages relating to transactions or services you have specifically requested, responding to any email from you to us, notifying you of updates or changes to our policies and procedures, or which otherwise provide you with information we believe is important to users. Our systems require time to update, so your opt–out requests may not update immediately. Please note that if you do opt–out, we will not be able to remove personally identifiable information from the databases of third parties with which we have already shared such information. If you wish to cease receiving marketing–related emails from third parties, please contact third parties directly or utilize any opt–out mechanisms set forth in their respective privacy policies or marketing related e–mails.

10. SPECIAL NOTICE REGARDING CHILDREN

The XOGAMES Products are not designed for nor do we knowingly collect personal information from children under the age of 13. If you are under 13, please do not attempt to send any information about yourself to us, including your name, address, telephone number, or e–mail address. Parents or legal guardians may contact support@xogames.co.kr for questions or concerns.

11. LINKS TO OTHER WEB SITES OR APPLICATIONS

Links from the XOGAMES Products to third party Web sites or applications are provided for your convenience. In addition, content in XOGAMES Products may be hosted by other websites or applications. Any personal information you provide on the linked pages or applications is provided directly to that third party and is subject to that third party's privacy policy, not ours. These other sites and applications maintain their own policies regarding cookies and the collection and use of personal information. It is up to you to review those policies yourself.

12. CONTACT INFORMATION TO CORRECT AND UPDATE PERSONAL INFORMATION OR OBTAIN ADDITIONAL INFORMATION

If you have any questions or comments about this Policy or our practices relating to the XOGAMES Products or you wish to verify, correct or delete any personal information we have collected, please contact us at support@xogames.co.kr. We will endeavor to respond to your inquiry or information request to the extent possible.

13. CALIFORNIA RESIDENTS: CALIFORNIA CONSUMER PRIVACY ACT DISCLOSURE

These California Consumer Privacy Act Disclosures (“Disclosure”) are effective as of the date above. Any capitalized terms used herein shall have the same meaning as under the Privacy Policy.

Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights regarding their personal information. This Disclosure describes such rights and how you may exercise them in accordance with the CCPA.

Categories of Personal Information Collected or Disclosed for a Business Purpose.

In the 12 months preceding the date of this Disclosure, we may have collected and/or disclosed for a business purpose the following categories of personal information as enumerated under the CCPA:

Identifiers, including name, postal address, email address, and online identifiers (such as IP address);
User records, including phone number, billing address, and credit or debit card information;
Characteristics of protected classifications under California or federal law;
Commercial or transactions information, including records of products or services purchased, obtained, or considered;
Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement;
Geolocation data;
Professional or education information;
Inferences drawn from the above information about your predicted characteristics and preferences.

Your Rights Regarding Your Personal Information.

If you are a California resident, you have the right under the CCPA to submit a verifiable request of the following:

The specific pieces of your personal information collected by XOGAMES in the 12 months preceding this Disclosure;
The categories of personal information we collected, sold, or disclosed for a business purpose about you within the 12 months preceding this Disclosure;
The categories of sources from which the personal information was collected;
The business or commercial purpose for which the information was collected or sold;
The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared;
Deletion of your personal information collected by XOGAMES.
How to Exercise Your Rights
- To exercise any of these rights, please email us at support@xogames.co.kr. In the request, please specify (a) which right you wish to exercise and (b) the scope of your request. We will confirm receipt of your request within 30 business days. We may require specific information from you, which may include personal information about you or information about your past purchases or use of our products or services, in order to help us verify your identity and process your request. Your request may be denied if we are unable to verify your identity.
Deletion Requests.
- If you request deletion of your personal information, we may retain personal information necessary to: (a) protect our business, systems and users from fraudulent activity, (b) to address technical issues that impair existing functionality, (c) allow us or others to exercise their free speech or other rights, (d) comply with law enforcement requests pursuant to lawful process, (e) support our own internal purposes reasonably related to your relationship with us, (f) to comply with legal obligations, or (g) otherwise as permitted by law and disclosed to you when we respond to your request.
Authorized Agent.
- You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise your rights and choices on your behalf, please provide written proof of your agent’s permission to do so. A request from an agent may be denied if such agent does not submit proof that the agent was authorized by the user to act on the user’s behalf, and/or the agent’s identity could not be verified.

No Sale of Personal Information.

We do not “sell” information for money or other valuable consideration. We disclose personal information for the business purposes set forth in the Privacy Policy(please refer to Section II (USES OF PERSONAL INFORMATION) and Section III (SHARING OF PERSONAL INFORMATION)).

No Discrimination.

XOGAMES will not discriminate against any user for exercising their rights under the CCPA, although some of the functionality and features available on the Services may change or no longer be available. Any differences in the Services are related to the value provided.

14. P3P

Please note that some of our XOGAMES Products support "P3P" or the Platform for Privacy Preferences. If the terms of the Platform for Privacy Preferences or our XML P3P code should for any reason ever differ from the terms of this Privacy Policy, the terms of this Privacy Policy shall control.

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