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Ring of Elysium (DMM GAMES Version) Privacy Policy

Please note that Ring of Elysium (DMM GAMES Version) is only available to users located in Japan.

Last Updated: [April 20, 2020]

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us. Here is a summary of the information contained in this privacy policy. This summary is to help you navigate the privacy policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we need to provide the Game?
If you register an account to use the Game then we will need some information from you to set this up. We will also process some information when you use the Game (e.g., to make sure your progress is saved) and when you buy items (e.g., to ensure you get the purchased content). If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns.
More Information

How will we use your information?
We use your information to provide the many functions and services that comprise the Game. We do not share your information with any third parties, except where we need to in order to provide the service (e.g., use local cloud providers or to back up your data; using our affiliates around the world to help us to deliver the Game) or we are instructed to by a court, authority or compelled by law.

Who do we share your information with?
We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data). When we use a third party, we only do this to process or store your information for the purposes described in this privacy policy. We also have affiliates around the world who help us deliver the Game and we may be required by a court or legal obligation to disclose certain information in some circumstances.

Where do we process your information?
Our servers are located in Hong Kong, the United States, Singapore and Germany. Our support, engineering and other teams are located in our offices around the world (including the United States and the People’s Republic of China).

How long do we keep hold of your information?
We generally retain your information for the period during which you maintain an account for this Game after which time your data is deleted (as further described in this privacy policy), unless otherwise required by applicable laws.
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How can I exercise my rights over my information?
Depending on where you live, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data.

How to get in touch with us
If you have any questions about anything in this policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?
If there are any significant changes to this privacy policy, we will update the policy here.
More Information

Contact Information
You can contact us at ROE_DPO@tencent.com.

Welcome to Ring of Elysium on DMM GAMES (the “Game”)!

This privacy policy explains the when, how and why when it comes to processing of your personal information in connection with the Game, and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

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 using the Game. By using the Game you are accepting our rules regarding your personal information as described in this privacy policy.

This Game has been developed by the Tencent group (“we”, “us”, “our”). Our data protection officer can be contacted at ROE_DPO@tencent.com.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at ROE_DPO@tencent.com.

The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information” below.

The following is a high level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party).

This Game is hosted on the DMM GAMES platform operated by EXNOA LLC (referred to as "DMM GAMES"), which is not part of the Tencent group. When you register for this Game, DMM GAMES generates a DMM ID for your account and we receive this from them.

2. Information about you generated as part of the Game (and its in-Game services)

We automatically collect certain data from you so that we can provide you with the many functions and services that comprise the Game. This includes your account ID (a unique number that we generate), your IP address and information about your device. This Game also incorporates a security feature to help us maintain a fair playing experience for all players. This security feature collects information about the device, network and system on which you are playing this Game.

When you play the Game you also generate information personal to your gameplay, including statistics and your virtual character. We collect and store this information, as well as log data that records how you use the Game.

We also collect and store your data if you choose to use certain additional features of the Game including:

  • • If you want to conduct any transactions within the Game (e.g., buying items via in-game purchase).
  • • If you enable the chat feature, we process your chats and chat log data (e.g. time of chat and who you chat with) in order to allow you to communicate with other users.
  • • If you reach out to our support team. In order to establish what is wrong, and how to correct it, we will need to collect your email and information about your device, network and system. We may also report back to you using the email you provided when contacting our support team.

Children

If you are under the age of 16 then unfortunately you are not permitted to use the Game.

We do not knowingly collect personal information from children under 16 for any purpose. If you believe that we have personal information of a child under this age, please contact us at ROE_DPO@tencent.com and we will delete such information.

How We Use Your Personal Information

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

Personal Information Use
Game
Information you provide to us (either directly or through a third party).
DMM ID We receive your DMM ID from Steam when you create your account for this Game.
Information generated as part of the Game (and its in-Game services)
Account ID We use your account ID to set up your account, improve our services and provide operational support.
IP Address We use your IP Address to provide the Game to you, improve our services and provide operational support.
Advertising ID We use your advertising ID to improve our services and provide operational support.
Device information: hardware specifications (including OS version), network information, information about your internet or WiFi connection, country code, and application version We use your device information to maintain your account and the Game services on different devices.
Security-related information: basic hardware information, operating system information, machine codes for security authentication, user account information, network information, information of files, processes, modules, memory and driver which is related to the game running, user behaviour and status that may be related to plug-in use, image files, memory image and shellcode which is related to the game running, system API calls, method calls, system procedures and related data of active windows, information on in-game modules, game screenshots, external programs attempting to access private data which belongs to process of game application. We use this information:
• for security purposes, including to detect cheating behaviours;
• to provide a fair Game environment; and
• to solve Game crash and to improve our services.
Transaction information: Steam ID, country/region code, currency code, in-game language code, order ID, IP address, price and item information We receive this information from Steam. Of this information, we store the time, order ID, IP address, price and item information of in-Game purchases.
We use this information to facilitate your payment and to maintain a record of your purchase history.
Chat log data We use this information to enable your communications with other users.
Customer support information: ticket ID, information provided by you when contacting our customer support team which may include information about your device, network and system, your email address We use this information to:
• improve our services;
• provide troubleshooting, such as addressing and remediating technical issues and bugs.
Game data: account ID, nickname, character ID, details about your virtual character, server, channel, and Game play statistics such as your level, characters, score/s We use this information to provide you with feedback and information about your Game play and progress, and to save your Game data for future play.
Game log data: account log in and log out times and access to the Game room We use this information to:
• maintain a record of log-in and actions of your account;
• improve our services, including the functionality of this Game; and
• for troubleshooting purposes.

We may collect other personal information from you from time to time for specific reasons (such as a promotion in your country). When this happens, we will provide more information on any specific changes to the way we process that personal information that might differ to this privacy policy prior to collecting or processing any additional information. In some cases, that information may be shared with us with your consent – and if that is the case, we will provide you with further information on how we process that information and your rights.

How We Store and Share Your Personal Information

The Tencent group operates around the world. Pursuant to our contract with you to provide you with this Game, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers for this Game are located in:

  • • the United States;
  • • Hong Kong;
  • • Singapore; and
  • • Germany.

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 this Game, including providers of cloud services that process information identified in this privacy policy on their servers for the purpose of providing this Game. All third party service providers are prohibited from using your personal information for any purpose other than providing us with their services.
  • Companies within the Tencent corporate group who process your personal information in order to operate this Game. All related group companies may only use your personal information in accordance with this privacy policy.
  • Regulators and judicial authorities and law enforcement agencies. There are circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users.
  • A third party that acquires all or substantially all of us or our business. If we sell or buy any business, undergo a merger, enter into a partnership, or sell some or all of our assets we may disclose your information to the prospective buyer of such business. Under these circumstances, we will always require the prospective buyer to comply with this privacy policy.

Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. 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 do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

Data Retention

Personal Information Retention Policy
DMM ID.
Account ID.
IP Address.
Advertising ID.
Device information*.
Transaction information*.
Chat log data*.
Customer support information*.
Game data*.
Game log data*.
Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for 30 days.
Security-related information*. We generally retain this data for no longer than 90 days with the exceptions listed below. Upon a deletion request, we will delete the data within 30 days except where they relate to confirmed malicious activities.
File sample collection and memory sample collection related to confirmed malicious activities: up to 10 years
In-game process information and system information: up to 10 years.
Security authentication: up to 5 years.

*Full description of data is set out in the section “How We Use Your Personal Information” above.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

Your Rights

You may request us to notify 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 at ROE_DPO@tencent.com.

Announcements

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

Contact & Complaints

We welcome questions, comments and requests regarding this privacy policy. Please address them to ROE_DPO@tencent.com. Please include the word “DMM GAMES Version” in the subject line of your email.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at ROE_DPO@tencent.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you consider we have infringed data protection laws.

Changes

If we make any material changes to this privacy policy, we will post the updated privacy policy in-game. Please check frequently to see if there are any updates or changes to this privacy policy.