Gravity Game Vision Limited 

PRIVACY POLICY

(Effective Date: December 20, 2023)

Gravity Game Vision Limited (“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 may decide to provide to us in your use of: (1) our website(s) (our “Sites”), (2) our application named RO Origin (in Chinese “仙境传说：爱如初见”) (the “Application”) as an Mobile game which can be played by End Users on a feature phone, smartphone, PDA, tablet computer, portable media player or other handled devices (“Mobile Devices”) and is operated in certain hardware environment with such operating system, including, without limitation, Android, IOS and Windows phone, 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 individually as the “Service” and collectively as the “Services”.  

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 DO NOT ATTEMPT TO ACCESS ANY OF OUR APPLICATIONS OR RELATED PRODUCTS OR SERVICES IF YOU RESIDE IN EUROPE.  COMPANY DOES NOT PROVIDE ANY SERVICES TO USERS(S) IN EUROPE.

Notwithstanding any provision herein, under any circumstance, the countries embargoed by the United States or the countries set forth on “the U.S. Treasury Department’s list of Specially Designated Nationals or the U.S. Department of Commerce Denied Persons List or Entity List” shall be clearly excluded from the scope of the country or individual to which our Services are provided.

Collecting Personal Information

Our primary goal in collecting the information described below is to provide you, the 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.  

Information Collected Directly From You

Registration Information.  When you communicate directly with us, either through the Application, at our Site or a Network or 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) password and other information necessary to ensure security of your account; and (v) such other information you choose to provide to us such as billing information, profile photo, photo representation (avatar), character name, interests and hobbies, game play preferences, and links to profiles on various SNS.  

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 include 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 inviting 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 and; (viii) 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 Applications and Third Party Mobile Applications 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 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 such online application distribution system as App store, Google Play etc. (“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 Applications on an SNS.

2. How We Collect Personal Information

Automated 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.  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 on 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 better understand 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 Hong Kong 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.  

We may provide your personally identifiable information to our “Affiliates”(which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership located in the United States, Japan or anywhere else in the world, excluding European regions except for Russian Federation and CIS), for the purpose of transferring and processing such information based on our instructions under such purposes as described in this Privacy Policy and in compliance with this Privacy Policy and other appropriate confidentiality and security measures.

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:   

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 a 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, 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 Hong Kong 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 Terms

Opt-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 at  [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, citation, 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 terminate 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.

Notification of Changes

We reserve the right to update and change the terms of this Privacy Policy at any time.  If we decide to update and materially change the terms of our Privacy Policy, we will post those changes in our Services and/or on the applicable Sites, and in the updated Privacy Policy. You should periodically check this Privacy Policy for updates.  

By continuing to access or use the Services after we have posted an updated Privacy Policy or have provided you with notice of a modification, you are agreeing to be bound by the modified Privacy Policy.  If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.

Links to Third Party Websites, Services and Offers.

Our Service may contain links to other websites, services and/or offers from third parties. We are not responsible for, nor will it be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information you voluntarily chose to provide to them. You should review the applicable privacy policies and information practices of such third parties carefully before providing personal information to them.  Moreover, if you have any questions or concerns, you should contact the third party directly.

Protection of Children’s Privacy

Children who reach the age (“Competent Age”) to give valid consent under his/her relevant national law or who does not reach the Competent Age but gets valid consent from their legal representative (e.g. parents) can only use the Application. We make reasonable efforts to verify if consent from or any contract concluded with such children is valid by offering users age verification methods and by obtaining clear consent from children’s legal representatives. If we learn that we have inadvertently gathered Personal Data from such children, we will take reasonable measures to promptly erase such information from our records. If children under Competent Age or their legal representative ask us to cease processing or profiling of the child’s Personal Data for the purposes of direct marketing, we will immediately do so.

Special Note to Parents

If you become aware that your child has provided us with personal information at our Service, we invite you to notify us so that we may delete the information from our records and discontinue any related features or services (see Opt-Out Provision above).  We also urge parents to instruct their children never to give out their real names, addresses or phone numbers without parental permission when using the Internet. We appreciate your cooperation in assisting us to provide a safe and enjoyable online experience for your children.

Users Outside Hong Kong

The Company is a Hong Kong company and Company’s business operations are primarily conducted in Hong Kong. We operate our company and administer this Privacy Policy under applicable laws and regulations of Hong Kong.  If you use our Service from outside Hong Kong, you are thereby consenting for your personal information to be transferred to, stored in and be processed in Hong Kong and/or in other countries by the Company and/or its Affiliates in the manner described in this Privacy Policy.  Your consent to this Privacy Policy followed by your submission of your personal information represents your agreement to such transfer, storage and processing of information.  

As described elsewhere in this Privacy Policy, when you submit personal information via our Service, the information is housed in secure databases, equipment and servers located Hong Kong and/or in other countries.  The databases, equipment and servers we utilize may be owned by third party providers.  

Users in certain jurisdictions may have a right to access his/her personal information held by the Company and/or its Affiliates. Your right of access to such personal information can be exercised in accordance with applicable laws, rules and regulations.  

Company officially notifies that Company does not provide any Services to a European User. If you are a European User, please do not attempt to access Services or to play any game on or through any service of Company. Further, if you newly acquire the nationality, or at any reason at all, by which you become a European User after your using Services, you should notify such fact to Company for our terminating your access to the Services under the condition of the relevant TERMS OF SERVICE or this Privacy Policy.

Company warrants and guarantees transfer of personal data on a lawful basis in accordance with requirements of applicable laws, rules and regulations, including, but not limited to Regulation the California Consumer Privacy Act of 2018 (the “CCPA”), the General Personal Data Protection Law (Portuguese: Lei Geral de Proteção de Dados Pessoais, or “LGPD”; Lei 13709/2018). If you are a California resident, please see “Further Information for Users in California” in Appendix 1 below. Further, if you are a Brazil resident, please see “Further Information for Users in Brazil” in Appendix 2 below.

Please submit any requests for such access to [email protected].

Language

The controlling language of this Privacy Policy is English.  If you have received a translation into any other language, it has been provided for your convenience only.  The English version of this Privacy Policy shall govern to the extent of any inconsistency between the English version and any translated version.

Contact Us

If you have any questions, inquiries, requests, complaints, or comments regarding this Privacy Policy, or have other questions or suggestions about our information practices, please contact us via e-mail at [email protected] 

© Gravity Game Vision Co. Ltd. All rights reserved.

Appendix 1: Further information for Users in California

This section of the document (“Notice”) integrates with and supplements the information contained in the rest of the Privacy policy for Residents in California and is provided by the Gravity Game Vision Limited (“Company,” “we,” “our,” or “us”) operating and servicing the game named RO Origin (the “Application”). This Notice applies solely to all visitors, users, and others who use the Service and reside in California (“consumer,” “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice. This Notice also applies only to the information that we collect through (1) our website(s) (our “Sites”) (2) 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”.  

1. INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).  In particular, through your use of the Service, we have collected the following categories of personal information within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records;

• De-identified or aggregated consumer information;

• Information excluded from CCPA’s scope, like personal information protected by other certain sector-specific federal or California statutes.

2. HOW WE COLLECT PERSONAL INFORMATION

We obtain the categories of personal information listed above from the following categories of sources:

• Directly From You: The information you provide while using the Service.

• Indirectly From You: We collect certain technical information, like the Internet Protocol address, when you access and use our Service.

• Collected and/or Received From Third Parties: We may collect your data from third parties, such as when processing your purchases through our Sites or Apps or when you access our Service through a social networking service (“SNS”).

• Collected Through Mobile Devices: When you use our Apps on your mobile telephone or other mobile device (“Mobile Device”), you are authorizing us to collect, store, use, and/or share, in addition to the information described above, the Mobile Device type; mobile carrier; platform version; navigation, interaction, and engagement information regarding our users; and other information you choose to provide to us.  Also, we receive and store information you provide when you sign up to have Short Message Service (“SMS”) notifications sent directly to your Mobile Device.

3. HOW WE USE PERSONAL INFORMATION

We may use the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information;

• To provide, support, personalize, and develop our products and services for and through our Service;

• To create, maintain and service accounts;

• To provide customer service;

• To process your requests and payments and fulfill orders and transactions;

• To verify consumer information;

• To personalize your Site, App, and Forum experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Service and via email or text (with your consent, where required by law);

• To provide advertising and marketing services;

• To provide analytic services;

• To detect and respond to security incidents;

• To improve our Service;

• For testing, research, analysis, and product development;

• For auditing related to a current interaction with the user and concurrent transactions, including but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards;

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;

• As described to you when collecting your personal information or as otherwise set forth in the CCPA;

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Service’s users is among the assets transfers.

Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4. SHARING PERSONAL INFORMATION

Company may disclose your personal information to a third party for a business purpose.  When we disclose your personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep your personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates;

• Our Partners

• Service providers;

• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

5. DATA SECURITY

We have implemented measures designed to secure and safeguard your personal information from accidental loss and from unauthorized access and disclosure. We maintain physical, electronic, and managerial procedures to limit access to your non-public personal information.

Unfortunately, the transmission of information via the internet is not completely secure.  Although we take reasonable precautions to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our Services or other electronic means. Any electronic transmission of personal information is at your own risk.

6. YOUR RIGHTS AND CHOICES

The CCPA provides California residents with specific rights regarding their personal information.  This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months.  Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you;

• The categories of sources for the personal information we collected about you;

• Our business or commercial purpose for collecting that personal information;

• The categories of third parties with whom we share that personal information;

• The specific pieces of personal information we collected about you (also called a data portability request);

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

o sales, identifying the personal information categories that each category of recipients purchased; and

o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

• Debug products to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

• Comply with a legal obligation;

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Visiting: lna.roglobal.com

• Emailing us at: [email protected]

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.  You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.  We will use only personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.  We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

7. NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights.  Unless permitted by the CCPA, we will not:

• Deny you goods or service;

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

• Provide you a different level or quality of goods or services;

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.  Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects.  Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

8. CHANGES TO OUR PRIVACY NOTICE

Company reserves the right to amend this Privacy Notice at our discretion and at any time.  When we make changes to this privacy notice, we will update the Privacy Notice’s effective date, and notify you via email at the last email address that you provided us and post the updated notice on the Sites.  Your continued use of our Service following the posting of changes constitutes your acceptance of such changes.

9. CONTACT INFORMATION

If you have any questions or comments about this Privacy Notice, the ways in which Company collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: lna.roglobal.com

Email: [email protected]

Postal Address:

Gravity Game Vision Limited

Rm1501-08, Millennium City 5, 418 Kwun Tong Road, Kwun Tong, Kowloon, Hong Kong 

Appendix 2: Further information for Users in Brazil

This section of the document (“Notice”) integrates with and supplements the information contained in the rest of the Privacy policy for Residents in Brazil and is provided by the Gravity Game Vision Limited (“Company,” “we,” “our,” or “us”) operating and servicing the game named RO Origin (the “Application). This Notice applies solely to all visitors, users, and others who use the Service and reside in Brazil (“you”). We adopt this Notice to comply with the General Personal Data Protection Law (Portuguese: Lei Geral de Proteção de Dados Pessoais, or “LGPD”; Lei 13709/2018) and any terms defined in the LGPD have the same meaning when used in this Notice. This Notice also applies only to the information that we collect through (1) our website(s) (our “Sites”) (2) 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”.  

The Brazil Representative of Controller under Art. 41 LGPD can be reached at:

Company Name: DPO OFICIAL (Vetaluti Consultoria e Assessoria Ltda.)

Official Address: Ferdinando Ramponi street, 88 – São Paulo/SP

Phone: 166.869.838-29

Contact Email: [email protected]

1. THE GROUNDS ON WHICH WE PROCESS YOUR PERSONAL INFORMATION

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

•             your consent to the relevant processing activities;

•             compliance with a legal or regulatory obligation that lies with us;

•               the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;

•             studies conducted by research entities, preferably carried out on anonymized personal information;

•            the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;

•            the exercising of our rights in judicial, administrative or arbitration procedures;

•            protection or physical safety of yourself or a third party;

•            the protection of health – in procedures carried out by health entities or professionals;

•            our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and

•            credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

2. CATEGORIES OF PERSONAL INFORMATION PROCESSED

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

3. WHY WE PROCESS YOUR PERSONAL INFORMATION

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

4. YOUR BRAZILIAN PRIVACY RIGHTS, HOW TO FILE A REQUEST AND OUR RESPONSE TO YOUR REQUESTS

YOUR BRAZILIAN PRIVACY RIGHTS

You have the right to:

•             obtain confirmation of the existence of processing activities on your personal information;

•             access to your personal information;

•             have incomplete, inaccurate or outdated personal information rectified;

•       obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;

•             obtain information on the possibility to provide or deny your consent and the consequences thereof;

•            obtain information about the third parties with whom we share your personal information;

•            obtain, upon your express request, the portability of your personal information (except for

anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;

•           obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;

•             revoke your consent at any time;

•              lodge a complaint related to your personal information with the ANPD (the National Data Protection

Authority) or with consumer protection bodies;

•              oppose a processing activity in cases where the processing is not carried out in compliance with

the provisions of the law;

•                  request clear and adequate information regarding the criteria and procedures used for an automated decision; and

•             request the review of decisions made solely on the basis of the automated processing of your

personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

5. HOW TO FILE YOUR REQUEST

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

6. HOW AND WHEN WE WILL RESPOND TO YOUR REQUEST

We will strive to promptly respond to your requests.

In any case, should it be impossible for us to do so, we will make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.

7. TRANSFER OF PERSONAL INFORMATION OUTSIDE OF BRAZIL PERMITTED BY THE LAW

We are allowed to transfer your personal information outside of the Brazilian territory with your consent under this Privacy Policy or any other arrangement, or in the following cases:

•        when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;

•             when the transfer is necessary to protect your life or physical security or those of a third party;

•             when the transfer is authorized by the ANPD;

•             when the transfer results from a commitment undertaken in an international cooperation agreement;

•            when the transfer is necessary for the execution of a public policy or legal attribution of public

service;

•            when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.