Privacy Policy

Last Updated: October 29, 2024

Thank you for using our products! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to the game Battle Aces (“Game”) and the main website for the Game (“Website”, which together comprise the “Service”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

*What information do we need to be able to provide the Service?*	In relation to the Website: · If you register to participate in the closed beta test of the Game, then we will need some information from you to register you for the Service. This includes your email, Steam account ID, region, and language preferences. · If you register to receive our newsletter and updates related to the Game, then you will need to provide your email address and language preferences. In relation to the Game: · If you register an account for or log in to the Game, then we will need some information from you to allow you to access the Service. This includes your Steam account ID, IP Address (not stored on server but just processed). · To maintain the smooth operation of the Service (which includes activities such as troubleshooting and analytics), we will process customary device and network information (such as IP address as well as app- and OS-generated identifiers) and your Steam account ID and country and language settings. · If you need to get in touch with us, we will retain some information (such as your email) so that we can review and respond to your concerns.	More Information.
*How will we use your information?*	· We use your information to register you for the Service, enable you to access the Service, and to comply with our legal obligations and enforce our legal rights.	More Information.
*Who do we share your information with?*	· We use third parties and work with our affiliates to help us deliver the best possible experience (such as for cloud storage and platform services, survey, and to provide marketing services). · All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., to fulfil the purpose(s) described above). · In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.	More Information.
*Where do we process your information?*	· Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. · We have servers for the Service in the United States of America, Belgium and Singapore. We also have support, engineering and other teams who may support the Service from the United States of America. · For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.	More Information.
*How long do we keep your information?*	· Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Service, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.	More Information.
*How can I exercise my rights over my information?*	· Certain jurisdictions offer participants specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.	More Information.
*How will we notify you of changes?*	· Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.

Welcome to the Battle Aces!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the game Battle Aces (“Game”) and the main website for the Game (“Website”) (the Game and the Website, together comprise the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Service. If you use any other products or services please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop registering for the Service. By registering for the Service, you are acknowledging how we process your personal information as described in this Privacy Policy.

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited (“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at DPO@uncappedgames.com.

1. Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. For more information about our Cookies policy, click here.

2. Children

Children must not register for the Service for any purpose.

By children, we mean participants under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

We do not knowingly collect personal information from children under such age for any purpose. If you believe that we have personal information of a child under such age without lawful consent, or if you are the parent or guardian of the participant and wish to withdraw consent, please contact us.

Region in which the participantis located	Minimum age of the participant
Algeria	19
Argentina	13
Australia	18
Bangladesh	18
Brazil	18
Cambodia	18
Canada	13
Colombia	18
Egypt	18
European Economic Area	16
Hong Kong	18
India	18
Indonesia	18
Japan	18
Kazakhstan	18
Kuwait	21
Macau	18
Malaysia	18
Mexico	18
Morocco	18
Myanmar	18
New Zealand	16
Nigeria	13
Philippines	18
Qatar	18
Republic of Korea	14
Saudi Arabia	18
Serbia	15
Singapore	13
South Africa	18
Sri Lanka	18
Switzerland	14
Thailand	20
Tunisia	18
Türkiye	18
United Arab Emirates	21
United Kingdom	13
United States	13

3. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

For users who live in Brazil, the European Economic Area, Indonesia, Switzerland, Thailand, Türkiye or the United Kingdom it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (where applicable)
In relation to the Website
Information you provide to us (either directly or through a third party)
Registration data to the closed beta test of the Game: Email, Steam account ID, region, language preferences	We use this information to register you to the closed beta test of the Game in accordance with your request.	Necessary to perform our contract with you to provide the Service.
Registration data for newsletters (optional): Email, language preferences	We use this information to send you newsletters about the Service if you have opted in.	We process this information with your consent.
Survey: User and contact information (age, gender, email, address, mobile number, selected country / location, Steam ID, device information (phone model, device configuration preference), game information (game habits and preferences (including recently played games, game duration and favourite game categories and experience, language preference, etc.), preferred social media, and other content of survey responses user may choose to provide. If you choose to participate in a survey hosted on third parties’ platforms or otherwise conducted by third-party service providers, their terms of use and privacy policy also apply to the data processed.	We use the survey information to facilitate your participation in surveys about the Service and to improve the Service.	We collect this information with your consent.
In relation to the Game
Information you provide to us (either directly or through a third party)
Account log in data: Steam account ID, IP Address (not stored on server but just processed)	We use this information to allow you to login to the Service.	Necessary to perform our contract with you to provide the Service.
Data to add Steam Friends (optional): Steam account ID, nickname, avatar.	We use this information to allow you to add your Steam friends in the Game.	Necessary to perform our contract with you to provide the Service.
Data to allow spectators to watch friends’ matches Steam account profile name, gameplay activities, deck, match outcome	We use this information to allow you to watch friends matches in the Game.	Necessary to perform our contract with you to provide the Service
Emotes (quick-messages) Steam account ID Profile information (avatar and nickname) Quick Messages (not stored).	We use this information to allow you to use Emoes feature in the Game.	Necessary to perform our contract with you to provide the Service
Information generated as part of the Service
Telemetry messages: Steam account information (Steam account ID, country, language settings), device information ([MAC address], device model, hardware brand and model, unique device ID)	We use this information for troubleshooting and to solve issues with the Service, and for analytics.	It is in our legitimate interest to ensure the Service is made available to you in an efficient and error-free manner.
Game Logs / Crash Logs: Steam account ID, Client Device Information (OS name/version. screen resolution. Hardware info including: graphic card, directx version, processor type, disk storage size, memory size), Steam Profile name.	We use this information to solve bugs and service issues.	It is in our legitimate interest to ensure the Service is made available to you in an efficient and error-free manner.

4. How We Store and Share Your Personal Information

We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Service in the United States of America, Belgium and Singapore. The servers applicable to your use of the Service will depend upon your choice of server and/or location. We also have support, engineering and other teams who may support the Service from United States of America and Singapore.

For EEA/UK users, transfers to our affiliates and third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

Third parties that provide services in support of the Service, including providers of services that process information identified in this policy for the purpose of providing the Service, providing cloud storage and platform services (such as Google Cloud, Steam), troubleshooting services (SmartBear), and providing marketing services (such as ActiveCampaign). All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., for the purpose(s) described above).
Companies within our corporate group who process your personal information solely for the purpose of providing the Service to you. All such group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:

enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our participants, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

5. The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.

6. Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
Account log in data	Steam ID: retained until the Game is no longer in operation, or in accordance with user's request, upon which it will be deleted within 30 days. IP address: We do not store this.
Registration data to the closed beta test of the Game	Stored for the lifetime of your use of the Service, unless they request deletion of your Game account or data, upon which such data would be deleted within 30 days. Such data will also be retaind by Steam in accordance with Steam’s privacy policy.
Registration data for newsletters	Stored for the lifetime of your use of the Service, unless you unsubscribe to our newsletters or you request deletion of your Game account or data, upon which such data would be deleted within 30 days.
Telemetry messages	Account ID and country: Stored for the lifetime of the Service. Steam ID retained until the final Game is no longer in operation, or in accordance with user's request, upon which it will be deleted within 30 days.
Game Logs / Crash Logs	Stored for a maximum of 120 days from game/crash log creation.
Data to add Steam Friends	Not stored by the Service. Stored on your device and in accordance with Steam privacy policy.
Data to allow spectators to watch friends’ matches	Not stored by the Service. Stored on your device and in accordance with Steam privacy policy
Emotes	Not stored by the Service. Stored on your device during the game activity
Survey	Stored for a maximum of 1 year or in accordance with user's request, upon which it will be deleted within 30 days.

7. Your Rights

Some jurisdictions’ laws grant specific rights to participants of the Service. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.

Access

You may have the right to access personal information we hold about you, how we use it, and who we share it with.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.

Correction

You may have the right to correct personal information we hold that is inaccurate.

Erasure

You may be able to delete certain personal information that we hold about you. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at DPO@uncappedgames.com or using the contact details set out below, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at DPO@uncappedgames.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.

Advertising

You may choose to stop receiving personalised advertising or marketing promotions from us when using the Service, by following the opt-out instructions included in the Settings section of the Service or our emails, or by contacting us.

8. Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: DPO@uncappedgames.com

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

9. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

10. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.

Our Representatives in Certain Jurisdictions:

Jurisdiction	Representative	Address	Contact details
EU	Proxima Beta Europe B.V.	Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands	DPO@uncappedgames.com
UK	Image Frame Investment (UK) Limited	4^th Floor 80 Strand, London, United Kingdom WC2R 0RL	DPO@uncappedgames.com
Republic of Korea	Kite Bird Korea Yuhan Hoesa	25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea	DPO@uncappedgames.com
Serbia	Karanovic & Partners o.a.d. Beograd	Resavska 23, Belgrade, 11000, Serbia	local.representative@karanovicpartners.com
Thailand	Tencent (Thailand) Company Limited	8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand	DPO@uncappedgames.com
Türkiye	Özdağıstanli Ekici Avukatlık Ortaklığı.	Nidakule Ataşehir Kuzey Begonya Sok. No:3 Kat. 17 D: 162 34746 Ataşehir / İstanbul, Türkiye Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-Service conduct, suspensions, investigations, civil or criminal complaints.	turkeydatarep_proximabeta@iptech-legal.com

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Algeria

By using the Service, you give your consent to the collection, storage, treatment and use of your personal information, and transfer of your personal information to third parties or our affiliates to help us deliver the Service, in each case location in the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

Argentina

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar). While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing your personal information and by using the Service, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Australia

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients. You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to correct any of your personal information we hold that is inaccurate.

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Service] You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Service, including social media integration and in-Service purchases.

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).

Bangladesh

By acknowledging the Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by the Privacy Policy. You also consent to the cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

Brazil

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us. This may affect our provision of the Service to you.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as set out in Section 8 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

Colombia

Your authorization to process personal information for the Service may be expressed (i) in writing, (ii) orally or (iii) through unequivocal conduct that allows us to reasonably conclude that your authorization has been granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information. You can contact us to exercise any of these rights.

Egypt

By accepting the privacy policy or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country or region in which we have databases or affiliates, in particular to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

You also acknowledge your consent to receiving marketing messages from us, whether through e-mails or pop-ups or other such means.

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

France

Instructions for the processing of your personal data after your death. You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us as set out in Section 8 (Contact).

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to object to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

Where we permit any third parties to collect and use sensitive personal information, we shall use reasonable measures to ensure that the third parties do not further disclose such information to the extent required by applicable laws.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service. Where the processing of your personal data is not based on consent, our processing is based on certain legitimate uses as permitted under law and in compliance with applicable law.

Indonesia

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

In the event we fail to maintain the confidentiality of your personal information in the Service, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

By accepting the Privacy Policy, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

The categories of personal information specified in Section 3 (How We Process Your Personal Information) may include "special care-required personal information" (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us.

Kazakhstan

By accepting the Privacy Policy, you consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information as described in this Privacy Policy. The transfer of your personal information to third parties, which may include the cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, to the United States of America, Belgium and Singapore.

In the event of any discrepancy or inconsistency between the English version and the Kazakh version of this Privacy Policy, the Kazakh version shall prevail.

Your Rights

Right of access: You have the right to request access to and obtain a copy of the personal information we have processed about you or that is being processed on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.
Right to correction: You may request for the correction of your personal information or deletion of such personal information if it is impossible to correct it. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.
Right to blocking / de-blocking: You have the right to request the blocking of personal information related to you, if you become aware of a violation regarding the collection and processing of your data. If the violation has not been proved, you may request to de-block your data.
Right to deletion: You have the right to request deletion of your personal data if the collection and processing of your data has been conducted in violation of Kazakh laws.
Processing of your personal information in public sources of personal data: You may request to limit or provide your consent to the processing of your personal information in public sources of personal data.

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws) and storage of your personal information as described in this Privacy Policy.

Kuwait

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Macau

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Service to you. As a Macau data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Service, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by contacting us. However, this may affect our provision of the Service to you.

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Our data protection officer, responsible for the management and safety of your personal information

Telephone: +603-22872388
Email: as set out in Section 8 (Contact)

Mexico

Some of the purposes of processing specified in Section 3 (How We Process Your Personal Information) are voluntary, which may include to show you personalised recommendations or advertising. We may also use your personal data for the voluntary purpose of sending information to your email address or via SMS that we may consider relevant to you.

In general, we do not require your consent to carry out the transfers detailed in Section 4 (How We Store and Share Your Personal Information). In any case, by using the Service and providing us with your personal data, you agree to the data transfers detailed therein that require your consent.

To understand more about and exercise your rights to “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes limitation to the use and disclosure of your personal data, , and “Advertising” as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us.

Morocco

We collect information for purposes strictly necessary for the proper use of the Service. By accepting this Privacy Policy, you explicitly accept that your personal data may be subject to processing by the Service.

Kindly note:

the identity of the Data Controller is set out at the beginning of this Privacy Policy
the purposes of processing personal data are set out in Section 3 (How We Process Your Personal Information)
recipients or categories of recipients are set out in Section 4 (How We Store and Share Your Personal Information)
whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to Section 3 (How We Process Your Personal Information) and Section 7 (Your Rights)

New Zealand

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to request the correction of any of your personal information we hold that is inaccurate.

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Peru

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, pursuant to the Personal Data Protection Law (the “Law”). You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

Data Protection Team, responsible for the management and safety of your personal information
Contact: as set out in Section 8 (Contact)

Philippines

You are entitled to the following rights:

Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

By consenting to this Privacy Policy, you consent to us:

collecting and processing your personal information as described in Section 3 (How We Process Your Personal Information);
sharing your personal information with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
transferring or storing your personal information in destinations outside the Philippines as described in Section 4 (How We Store and Share Your Personal Information)

Qatar

If you are using the Service in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Republic of Korea

For the performance of the services detailed in this Privacy Policy, we delegate the processing of your personal information to the following professional service providers:

Delegatee	Description of Delegated Services
Google Cloud (Google LLC)	Storage of personal information
SmartBear Software (BugSnag) (SmartBear Software Inc.)	Bugs solving
Steam (Valve Corporation)	Access to Service (hosting the Game on the Steam platform)
ActiveCampaign (ActiveCampaign, LLC.)	Marketing services

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

Recipient (Contact Information of Information Manager)	Country to which Your Personal Information is to be Transferred	Date and Method of Transfer	Types of Your Personal Information to be Transferred	Purposes of Use by Recipients	Period of Retention of Use by Recipient
Google Cloud Google Cloud Privacy Policy	Singapore, Belgium, United States	Transferred via information and communications network at the time of service use	All personal information set out in Section 3 (How We Process Your Personal Information).	Storage of personal information	For the data retention period specified underthe section “Data Retention”
Steam Link Steam Privacy Policy	Depending on from where the Steam client is accessed (e.g., USA, Singapore, Germany, etc.)	Transferred via information and communications network at the time of service use	All personal information set out in Section 3 (How We Process Your Personal Information).	To host the Game on the Steam platform	For the data retention period specified underthe section “Data Retention”
SmartBear Software (BugSnag) SmartBear Privacy Policy	United States	Transferred via information and communications network at the time of service use	Game Logs / Crash Logs as set out in Section 3 (How We Process Your Personal Information).	To solve bugs and service issues	For the data retention period specified underthe section “Data Retention”
ActiveCampaign ActiveCampaign Privacy Policy	United States	Transferred via information and communications network at the time of service use	Registration data to the closed beta test of the Game, and Registration data for newsletters, as set out in Section 3 (How We Process Your Personal Information).	Deliver marketing emails	For the data retention period specified underthe section “Data Retention”

You may refuse the overseas transfer of your personal information by contacting our Data Protection Department. If you refuse the overseas transfer of your personal information, your personal information will not be transferred overseas. However, you may not be able to use our services for which overseas transfer of personal information is necessary.

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed in section “Data Retention”. With the exception of the personal information set out below, personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

The personal information detailed in section “Data Retention” are required to be retained pursuant to the following laws:

Act on the Consumer Protection in Electronic Commerce, Etc.

Article 6 of the Act on the Consumer Protection in Electronic Commerce

In an electronic commerce or a mail-order sale:

· Records regarding labelling and advertising (6 months)

· Records regarding execution or withdrawal of a contract (5 years)

· Records regarding the payment of a price and the supply of goods and services (5 years)

· Records regarding customer services or dispute resolution (3 years)

Protection of Communications Secrets Act

Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications Secrets Act

· Log records, IP address (3 months)

· The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Information Protection Act (“PIPA”). You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA. You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Additional Use and Provision of Personal Information

In accordance with the PIPA, we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc. We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information. Specific considerations are as follows:

whether the additional use/provision is related to the initial purpose of thecollection;
whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regardingprocessing;
whether the additional use/provision unfairly infringe on the interests of the data subject; and
whether the necessary security measures such as pseudonymization or encryption were taken.

Domestic Privacy Representative

Pursuant to the Article 32-5 of Network Act and Article 39-11 of the amended PIPA, the information regarding the domestic agent is as follows:

Name: Kite Bird Korea Yuhan Hoesa
Address: 25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea
Telephone:+82-2-2185-0926
Email: DPO@uncappedgames.com

Contact

Data Protection Department, responsible for the management and safety of your personal information
Telephone: +82-2-2185-0926
Email: DPO@uncappedgames.com

Serbia

Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.

Name: Karanovic & Partners o.a.d. Beograd
Address: Resavska 23, Belgrade, 11000, Serbia
Telephone Number: +381 11 3094 200
E-mail: local.representative@karanovicpartners.com

Singapore

By accepting this Privacy Policy, you consent to the collection, use and disclosure of personal data as set out in this Privacy Policy, including cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, the locations specified in Section 4 (How We Store and Share Your Personal Information). In situations where consent is not obtained, Proxima Beta collects, uses, or discloses personal data in accordance with an exception under the Personal Data Protection Act 2012 or as required or authorized by any other applicable law.

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted here.

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Sri Lanka

By accepting this Privacy Policy, you consent to the Privacy Policy and permit the collection, use and disclosure of your personal information.

Thailand

By accepting this Privacy Policy, you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the Service.

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;
request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;
request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or
lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us.

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in Section 8 (Contact) and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

Türkiye

You have legal rights, which are set forth in Article 11 of the Turkish Law on Personal Data Protection Law (“DPL”), in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

learn whether or not your personal data has been processed;
request information about processing if your personal data has been processed;
learn the purpose of processing of your personal data and whether they have been used accordingly;
know the third parties in the country or abroad to whom personal data has been transferred;
request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and
demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

Identity of the overseas recipient	Location of the recipient (or as otherwise stated in the recipient’s privacy policy)	Purposes of use of Personal Information by the recipient	Items of Personal Information to be provided
Google Cloud	Singapore, Belgium, United States	Storage of personal information	All personal information collected
Steam	Depending on from where the Steam client is accessed (e.g., USA, Singapore, Germany, etc.)	To host the Game on the Steam platform	All personal information collected
SmartBear Software (BugSnag)	United States	Bugs solving	All personal information collected
ActiveCampaign	United States	Marketing services	Registration data to the closed beta test of the Game Registration data for newsletters

Ukraine

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries or regions other than Ukraine, to the extent and for the purposes provided in this Privacy Policy.

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information, as described in the Privacy Policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

United States

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information, including sensitive personal information (denoted by *), from or about you or your device:

Identifiers, such as your name, IP address, Steam ID, device ID, device information, email address, country (location), and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.
Internet or other electronic network activityinformation, such as your information regarding your use of the Service and other Device Information as described in the main Privacy Policy. This information is collected directly from you and your device.
Geolocation information such as your region location when you set up your profile and choose to provide this information for the Service. This information is collected directly from you.

We collect and disclose your personal information, including sensitive personal information, for the following purposes:

To provide you with theService, create and maintain your account, provide customer service.
To allow you to access the Service.
To send you newsletters for the Service.
To improve our services, including the functionalityof the
For security and verification purposes, including to prevent and detect fraudulent activity.
To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see Section 3 (How We Process Your Personal Information).

We disclose each of the categories of personal information that we collect as described in Section 4 (How We Store and Share Your Personal Information)

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the CCPA, and we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services.

Retention of Your Personal Information

The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see above Section 6 in the main portion of the Privacy Policy.

Rights under US State Laws:

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:

the categories of personal information about you that we collected;
the categories of sources from which the personal information was collected;
the business or commercial purposes for collecting personal information about you;
the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
the specific pieces of personal information we collected about you;

Request to Delete. Request we delete personal information we collected about you;
Request to Correct. Request we correct inaccurate personal information that we maintain about you;
Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted advertising or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects; and
Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us as set out in Section 8 (Contact).

We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.

Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

Questions

If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 8 (Contact).

Privacy PolicyPrivacy Policy