Agreement on Using the Services and Privacy Policy

Agreement on Using the Services

Privacy Policy

ESTgames (hereinafter called as the “Company:”) regards personal information of the Users important and has been doing its best efforts to protect the rights and interests of the Users, establishing the policy of protecting personal information in accordance with the applicable laws and regulations.
Company informs the Users of how the personal information provided by the Users is used and protected by the Company. This Privacy Policy may be modified in accordance with the applicable laws or regulations or Company’s own policy and Company will announce modification of the Agreement immediately on the Company’s web site and games and explain the reason of modification and its details.
Article 1
Items of personal information collected and collecting method
Article 2
Collecting personal information and purpose of use
Article 3
Sharing and providing personal information
Article 4
Possession of personal information and period to use
Article 5
Procedures and method to destroy personal information
Article 6
Rights of the Users and legal representative and method to exercise the rights
Article 7
Installation/operation of automatic collecting equipment of personal information and refusal
Article 8
Technical/managerial protection of personal information
Article 9
Link site
Article 10
Public complaints about personal information
Article 11
Age Limits
Article 12
Others
Appendix

Article 1 Items of personal information collected and collecting method

Items of personal information to be collected ① Company collects following personal information to apply for membership and provide consultation for the customers and various services when applying for membership for the first time or using the services: – basic information allowed by SNS platform Facebook, inherent identification number of the users, name and gender of the users, profile photo or relevant URL of the users, inherent identification number of friends and other disclosed data, log-in e mail address provided when the users are registered in SNS, gender, date of birth of the users ② Following information may be created and collected in the course of using the services: – IP address, inherent number of device (device ID or IMEI) – Status information of the users, date and time of visit, records of using the services, record of bad use, payment information ③ Information on the credit card, carrier, details of purchase, number of gift card or other relevant information may be collected for payment, if it is unavoidable, while using free or paid services. Also additional personal information may be collected such as e mail address, details of purchase when the clients request restoration of paid Contents or refund to consult with the clients smoothly and real name and certifying family relation to verify the facts of making payment by others not by the User him/herself. 2. Collecting method ① Company collects personal information with following methods: – through platform services used for the services of the Company – Voluntary provision or input by the users when apply for the Services or during use – written format, fax, phone, consulting bulletin board or e mail

Article 2 Collecting personal information and purpose of use

1. Company uses the personal information collected for the following purpose: ① Performing agreement of providing basic services and settlement of the fee for providing the services – Providing contents, delivery of goods or invoice, certifying the users, purchase and paying the fee and collecting charges ② Management of members – confirm the users for using membership service and limited user indentifying system, identifying individuals, confirm the intension of joining as a member, restrict joining and frequency of joining – Preventing bad members from using (members whose agreement was terminated due to their breaching Clause 4, Article 9 and Clause 2, Article 15 of this Agreement) and unauthorized use. – Keeping records to settle disputes, solving public complaints and delivering notice ③ Development of new services and application for marketing/advertisement – Development of new services and provide customized services, verification of service effectiveness – Providing services according to the statistical characteristics and posting advertisement, statistics of using the services by members and their log-in frequency. – Providing event and advertising information and participating opportunity ④ Operating game app. of partner company, delivery of event gifts, supporting consultation with the customers

Article 3 Sharing and providing personal information

1. Company shall use personal information within the range announced at Article 2, Collecting personal information and purpose of use and does not exceed such range without prior approval of the Users thereupon nor disclose personal information of the Users in principle. However, personal information may be used and provided carefully if: ① User agrees upon in advance ② it is required to settle fee payment for the services ③ investigative agency requests it legally according to the laws or regulations ④ it is required for statistics, academic study or market survey and providing it in a form not to be able to identify specific individuals.

Article 4 Possession of personal information and period to use

1. Company shall destroy personal information collected immediately in principle when the purpose of collecting and using personal information is achieved to improve the services. Company, however, keeps the personal information for 30 days after the application for withdrawal from membership is submitted to the Company in preparation for unwanted application due to stolen personal information. Furthermore, Company shall preserve following information during specified period for specified reason and the information shall not be used for other purposes than the specified reasons: ① Reason of preserving information according to the Company policy – Record of illegal use (Reason of preservation: prevent illegal use / period of preservation: 1 year) ② Reason of preserving information according to the applicable laws or regulations If the information is required to be preserved according to the applicable laws such as but not limited to the Commercial Act or Act on the Consumer Protection in the Electronic Commerce Transactions, Company shall preserve the information of members for certain period as set forth in the applicable laws or regulations. – Record of visiting the services (Reason of preservation: Protection of Communications Secrets Act/ period of preservation: 3 months) – Records on the agreement or withdrawal from subscription (Reason of preservation: Act on the Consumer Protection in the Electronic Commerce Transactions/ period of preservation: 5 years) – Record on verifying the principal (Reason of preservation: Act on Promotion, etc. of Utilization of Information System/ period of preservation: 6 months) – Records on the payment and supplying goods (Reason of preservation: Act on the Consumer Protection in the Electronic Commerce Transactions/ period of preservation: 5 years) – Records on the complaints of consumers and settlement of disputes (Reason of preservation: Act on the Consumer Protection in the Electronic Commerce Transactions/ period of preservation: 3 years)

Article 5 Procedures and method to destroy personal information

1. Company shall destroy personal information collected immediately in principle when the purpose of collecting and using personal information is achieved. ① Destroying procedures – Information input by the users to apply for joining in the Services shall be destroyed, preserving it for certain period after the purpose of collecting is achieved and transferring to a separate DB, in accordance with the Company policy and the reasons to protect personal information according to the applicable laws or regulations (refer to Possession and Period of Use). – The said personal information shall not be used for other purpose than the reason of preservation except the case required by law. ② Destroying method – Personal information output in paper shall be crushed by a crusher or destroyed by incineration. – Personal information stored in electronic file shall be deleted by technical method in a way of impossible restoration.

Article 6 Rights of the Users and method to exercise the rights

1. Upon User’s request via e-mail, the Company will provide the User with the personal data and the user may change or request to modify the data to the Company. To protect User’s privacy and security, the Company will take reasonable steps to verify User’s identity before granting access or making changes or modifications. Unfortunately, the Company cannot always ensure that such changes or modifications will be reflected in all iterations of your information as previously stored. 2. When the users request correcting errors in their personal information, such information shall not be used or provided until correction is completed. Furthermore, if wrong personal information is provided to a third party, Company will notify the third party of correction without delay. 3. Company shall dispose of the personal information terminated or deleted by the request of the users or a legal representative in accordance with Article 5, Possession and period of use and such information shall be made not to be read or used for other purpose. 4. Users also have the right to use or restrict the data from being collected, and can use various options to control use and sharing of the personal information as following: ① Opt-out of Interest-Based Advertising - Users can opt-out of interest-based advertising on mobile applications by checking the privacy settings of Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android). For more information, see also: http://www.aboutads.info/choices and http://www.youronlinechoices.eu/. ② Opt-out options for notifications - Users may be able to adjust notification settings to opt-out from receiving any push notifications from the Services provided by the Company. ③ Geolocation Information - User’s device may enable the user to control the collection of the precise geolocation information through the settings on the mobile devices. ④ Cookies The Company may use cookies and similar technologies to provide and personalize the Service, analyse use, target advertisements and prevent fraud. - Users can delete or disable HTML cookies in browser settings of the personal device, but some parts of the Service may then not function properly.

Article 7 Installation/operation of automatic collecting equipment of personal information and refusal

1. Company may automatically collect device ID or IMEI when the users join in the services for the first time to provide personalized and customized services. Furthermore, Company may automatically collect inherent identification number and inherent identification number related to the list of friends from SNS platform to provide the function of registering friends or recommending friends. 2. If the users refuse collecting phone number and device ID automatically, some of the services cannot be used normally.

Article 8 Technical/managerial protection of personal information

1. Company implements following technical and managerial measures in processing personal information of the users to secure stability of personal information not to be lost, stolen, leaked, falsified or damaged: ① Measures against hacking – Company is doing its best efforts for personal information of the members not to be leaked or damaged by hacking or computer virus. Company backs up data in preparation for damaging personal information and prevents personal information or data of the users from leaking or being damaged. Also Company ensures personal information to be transmitted safely on the networks through encoded telecommunication. Unauthorized approach from outside is controlled by firewall system and Company is endeavoring to install all the possible technical equipments to make sure of the security systematically. ② Minimize number of employees processing personal information and education – Employees processing personal information are limited to those involved directly in the business and separate passwords which are renewed regularly are given to such employees, who are educated from time to time to comply with the Privacy Policy. ③ Operate an organization exclusively to protect personal information – Company checks whether Privacy Policy is properly implemented or not and compliance with the policy by the employees responsible for processing personal information through an organization exclusively to protect personal information. If any problems are found, Company corrects them immediately. Company, however, shall not be responsible for any problems occurred due to the leaked personal information by the users’ own fault or not by reasons of gross or intentional negligence of the Company.

Article 9 Link site

1. This Privacy Policy is not applied to the act collecting personal information from the web site of other companies or services linked with this site.

Article 10 Public complaints about personal information

1. Most concerns can be solved quickly by contacting us at cage@estgames.com 2. In the unlikely event that we cannot solve your concern and you wish to bring legal action against us these terms shall be governed by and construed in accordance with the laws of Republic of Korea.

Article 11 Age Limits

1. Children under 13 are not allowed to use any services provided by the Company. The Company does not knowingly collect personal data or direct or target interest based advertising to anyone under the age of 13. 2. If you are children under 13, please stop using the services provided by the Company. No one under the age of 13 may provide any personal data to the Company. 3. If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. 4. If you are a parent and you learn that your child is using the services provided by the Company and you don’t want them to, please contact us at cage@estgames.com.

Article 12 Others

Any addition, deletion or correction of this Privacy Policy will be announced at least 7 days prior to the date of enforcement on the Company’s web site or in the game services.

[Appendix 1]

This Privacy Policy shall be enforced on 5 month 24 day of 2018.
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