BATTLEGROUNDS MOBILE INDIA Privacy Policy

1. Introduction

KRAFTON, Inc. and/or its affiliates (“KRAFTON”, “we”, “Company” or “us”) keep and process information about you (“you”, “user”, or “player”) and other players who reside in the territory of India. We comply with all applicable laws related to personal information and strive to protect the rights of individual players by adopting this Privacy Policy (“Policy”) in accordance with relevant laws and regulations. This Privacy Policy describes how we collect and use personal information about you during and after your relationship with us.

2. Who We Are

We provide various video games and game services, including BATTLEGROUNDS MOBILE INDIA (the “Game” or “App”), the official site (“Site(s)”) and service related to the Game (i.e. event, survey, payment service or customer service) (“Service(s)”) to players.

3. Information We Collect

We collect information about you and the Services that you use. Information may also be required to enter into a contract with you or to perform a contract with you (such as to provide the Service at your request), and failure to provide any information may result in our inability to provide the requested services or products. The information we collect falls into three different categories: 1) information collected directly from you; 2) information collected automatically, and 3) information collected from third parties.

1) Information collected directly from you

You may provide us with the following information when playing our Game and/or using our Services. The information you provide to us may differ in some cases. For example, these may include:

- Nickname, phone number, etc. to provide the Game

- Nickname, email address, name, phone number, date of birth, etc. to register for tournament(s) or e-sports event(s)

- Nickname, email address, name, phone number, etc. to provide customer service

- Nickname, email address, name, phone number, gender, age, country of residence, survey responses, etc. for participation in survey(s), and other events

When you participate in social features (such as game chat), please note that the information that you disclose becomes public information and we may store and access it.

For some activities, we may ask you to set character information (such as the character’s date of birth, region, gender, etc.) which is considered non-personal information.

2) Information collected automatically

We automatically collect certain information when you play our Games and/or use our Services. The type of information that we automatically collect may vary, but generally includes:

– Device information (including IP address, device ID, device model, network type, OS version, time zone settings, screen resolution, etc.),

- Data during our Game play,

- Device event information, including crash reports and system activity details (e.g. whether you encountered an error playing our games or lost Internet access),

- Your browsing behavior while using our Site and/or Services

3) Information collected from third parties

When you access our Games and/or Services using a third party platform(such as Google, Apple, Game Center, Twitter, or Facebook). We collect certain information from your profile/account on the third party platform’s as permitted by the terms of the third party platform and your privacy settings thereon. For example, these include:

- Google: Google ID, nickname, profile image, purchase history

- Apple: Apple ID, profile image, purchase history

- Game Center: User ID, nickname, profile image

- Twitter: Twitter ID, nickname, profile image, friends list

- Facebook: Name, Facebook ID, profile picture, friends list

- Whatsapp: country code, phone number

4. Cookie and Related Technologies

We use cookies and other technologies to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes. Approved third parties may also set cookies and related technologies when you use our site or games.

1) Cookies

Cookies are small files downloaded to your device(if your browser is enabled to accept cookies) to track movements within websites and to customize your experience within the Site. Most Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of the Site may not function properly.

We do not control cookies in third party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. The ads appearing on the Site may be delivered to you by third-party advertising companies. These companies may use information about your visits to this and other web sites in order to provide advertisements on the Site and other sites about goods and services that may be of interest to you.

2) Website/Apps Analytics

We use analysis services on this site or apps to allow us to record information on the use of this Site and to constantly improve our offering.

This Site and the App uses Google® Analytics and related technologies, analysis services offered by Google Inc. (“Google”). We may use the following advertising functions of Google® Analytics and collect personal information as provided by Google, and you may withdraw your consent by deactivating such functions in Google’s advertising settings: Remarketing by using Google® Analytics; Google® Display Network Exposure Report; Google® Analytics Demographics and Interests Report; and Integrated service allowing the collection of data through Google® Analytics by using advertising cookies and anonymous IDs.

More information about Google’s own privacy policy can be found at https://www.google.com/policies/privacy.

If you wish to opt-out from your information or data being used by Google Analytics, you may download the Google Analytics Opt-out Browser Add-on available here: https://tools.google.com/dlpage/gaoptout

5. How We Use Your Information

We use the collected information for a variety of purposes, primarily, to provide the Game and the Service (collectively, the “Game Service”) to players like you and to improve the quality of the Game Service. These include:

- Operating the Game Service,

- Providing advertising information and other information on marketing and promotional events and surveys,

- Providing opportunities to participate on the events or surveys relating to the Game Service,

- Solving technical problems and improving the quality of the Service,

- Technical protection against usage of unauthorized programs,

- Preventing inappropriate gameplay that could harm other players,

- Analyzing usage data and service statics,

- Searching player statistics and provision of leaderboard,

- Operating E-sports events and providing opportunities to participate in tournament(s), and

- Providing customer service by collecting and responding to inquires.

In the majority of cases, processing of your personal information is:

- necessary to perform a contract with you or take steps to enter into a contract at your request: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our Service, we use your information to maintain your account and your profile and to provide the Service and customer support to you.

- in our legitimate interests, which are not overridden by your interests and fundamental rights: We may use your information where we have legitimate interests to do so. For example, we may analyze players’ behaviors in our Game and/or Services to continuously improve our Service. Also, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.

- necessary for us to comply with a relevant legal obligation: For example, we may process your personal information to comply with applicable accounting rules which require keeping accounting records and to make mandatory disclosures to law enforcement.

- consented to by you: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal by contacting us at the address provided in this Privacy Policy.

6. Sharing Your Information with Third Parties

We give permission to contracted third parties, including service providers which process personal information on behalf of us to provide customer support and to manage our community. We share your information only in the ways that are described in this Privacy Policy. We’ll share your personal information outside of KRAFTON when we have your consent. Here are examples of our third parties include:

- third party program restriction providers to block cheating tools and unauthorized programs

- cloud computing service providers to provide cloud storage services

- third party payment service providers (including but not limited to App Store, Google Play) to assist with payment for transactions or providing withdrawing service for sellers

- third party mobile advertising applications to serve and display in-game advertisements

- marketing platforms and providers of analytics services relating to players’ behavior, in order to tailor the Service and to conduct marketing activities

- online survey service providers in order to improve the game service

- customer service providers to respond to users’ inquiries

- E-sports events providers to hold and operate the E-sports events

- Mobile one-time password(OTP) authentication system provider to identify the users

We may also share your information where such disclosure is essential to comply with a legal obligation or a lawful data access request.

7. International Data Transfers

Your personal information will be stored and processed on our secure servers located in India and Singapore. The access to your personal information is limited to our employees’, agents and contracted third party, who are bound by strict confidentiality agreements and have access only on a business need to know basis. No one can access your personal information without our approval. However, we may electronically transfer your data, secured through multiple layers of security, communicated using leading encrypted technologies, to contracted third party service providers, who may be in different country or region, to operate the game service and/or to meet any legal requirements. The legal basis for such processing is compliance with a legal obligation to which we are subject to or are legitimate interests, such as exercise or defense of legal claims. In the event of transfer to another country or region, we will take steps to ensure that your information receives the same level of protection as if, it had remained in India.

8. Retaining and Deleting Personal Information

In principle, we will remove your personal information without delay after the purpose of collecting personal information is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using technical measures in a way that the information cannot be reproduced. However, we may retain your personal information even after you have closed your account with us or we have ceased providing Services to you, if retention of your personal information is reasonably necessary to comply with our statutory legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Privacy Policy or any other agreement we may have with a player. You have the right to request your personal information. You can delete your personal information via the in-game “Settings” - “Account” - “Delete Account” menu or visit our support page to request your rights. Also, if you want to withdraw your Marketing consent, you can opt out at any time by logging into your account and updating preferences under “Settings” - “Account” - “Withdraw”.

9. Our Policy Concerning Underage Users

This Game and/or Service are not intended for underage users. Thus, underage users should not use the Game and/or Service unless parental consent is provided. We do not knowingly collect, use or share any personal information for those who are under 18 years of age without the consent and verification of the underage users’ parent or guardian, or unless permitted by law. If you are under the age of 18 years, you will be asked to provide the mobile phone number of your parent or guardian to confirm that you are legally eligible to play the game. If you are a parent or guardian and you believe your child under 18 years of age has provided us with their personal information without your consent, you can contact us and request that your child’s information be deleted from our system.

10. Links and Third Party Services

If you click on a link to a third party website, including, without limitation, an advertisement, you will leave this Site and go to the site you selected. Because we cannot control the activities of third parties, we do not have responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website that is linked to the Site, you should consult that site’s privacy policy before providing any personal Information.

11. Security of Your Information

We have put in place appropriate security measures to prevent your personal information from being accidentally leaked, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, etc. who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place safety procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

12. Your Privacy Rights

Subject to limitations in applicable law, you may be entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information. Please note that some information may be exempt from such requests based on applicable law and your exercise of such rights may prevent you from continuing to access or use the Game Service. To make a request concerning your rights or if you have any other question, please contact us by sending an email to the address specified in the “Contact Us” section. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

13. Amendments

We may amend, at our discretion, any portion of this Privacy Policy at any time by posting or displaying the amended Privacy Policy on our Site. We will provide notice on our Site or by other appropriate means to you if these changes are material and, where required by applicable law. You will be deemed to have accepted such amendments by continuing to use the Service, so please review it frequently. You can see when this policy was last updated by checking the “effective date” displayed at the top of this policy.

14. Contact Us

If you have any questions about this Policy, or your dealings with this Site or App, please contact us by using one of the following communication channels.

- Grievance Officer Information

Name: Sanket Sarkar

Contact: battlegroundsindia_support@krafton.com