Vawraek Technology Inc. and its affiliated companies (hereinafter referred to as "Vawraek" or "Company") provide services (hereinafter referred to as "service"), such as gaming services and website services, whether PC, console or mobile, etc. In order to provide the services to users, the Company may store, process or, in certain cases, share the user's personal information. However, the company values the security of users' personal information and does its best to protect the personal information that users provide to use the services.
1. What Kind of Information Does Vawraek Collect and How?
The Company collects the following personal information through collection methods such as website membership registration, service usage (including mobile services), modification of membership information, phone call, fax, Player Support, event application, information collection tools supplied and created from partner companies.
1) Information Provided by the User
Vawraek collects the following information during membership registration.
- Email address (account name), password, name, date of birth.
The following information is collected during member registration with a Steam account.
- Steam ID number, Steam Username
The following information is collected when providing additional services.
- Player Support (Mandatory): Email address.
- Player Support (Preferred): Name-surname, e-mail address, date of birth, address, automatically generated information, other information required during counseling such as device identification information.
- Event/Promotion Participation Application (Preference): Name-surname, address, gender, date of birth, e-mail address.
- Gift Delivery (Mandatory): Delivery of Physical Products; Name-surname, address, mobile phone number. Delivery of Mobile/Inline Products; Mobile phone number, e-mail address.
- Notification of New Services and News (Preferred): E-mail address.
In addition, in special cases, additional personal information may be collected for the user depending on the service provided.
2) Information Collected During Service Use
The following information is automatically collected when using the Services.
- Data on your progress in the game
- Chat data, IP information, PC information (e.g. CPU type, RAM capacity, graphics card type, graphics card RAM, etc.)
- Game data and service usage data relating to interaction with other users during service use
- Error information, MAC address
- Game screenshots (in case of errors in the game client)
- Data collected through cookies and similar technologies
- Web browser information, general location data
- Advertising identity
- MAC address, HDD serial number
- Information needed to check payments
2. Why does Vawraek Collect Personal Information?
The Company collects and uses users' personal information to fulfill the following purposes.
1) Processes the data necessary to provide the service.
In order to fulfill the service provision agreement with the user, the Company processes the data necessary to fulfill the following purposes.
- In order for users to create accounts and use the services
- To operate the service
- In order to provide the products and services requested by users
- To be able to provide information about the services requested by users
- For payments for the purchase and use of paid services
- To comply with relevant laws
2) The Company collects data in order to provide a more appropriate service to users.
The Company has the right to collect and process the necessary information to achieve the following purposes in order to provide a more appropriate service to the user.
- For the improvement and development of the Company's services
- To enhance and improve the gaming experience with game service optimization
- To update and improve the user profile
- To set up and manage user-registered accounts
- To provide software updates
- To protect the user's settings and deliver content
- To respond to user questions and complaints and provide support
- To communicate notifications such as changes to the User Agreement, service errors, Player Support transactions, updates, security alerts and support messages
- To create events and promotional programs
- For the delivery of event and promotional gifts
3) The Company processes the data necessary to keep its services safe and fair.
The Company has the right to collect and process the necessary information to fulfill the following purposes so that users can benefit from the services in a safe and fair manner. Please refer to the User Agreement for the legal use policy.
- To prevent malicious and unauthorized use
- To provide services to protect the user's personal information
- To ensure a seamless gaming experience across multiple devices
- To automatically or manually allow an appropriate chat
- To find and fix bugs or service errors
- To investigate and deter disputes, fraud, illegal activities and to comply with relevant laws
4) The Company processes the data necessary to create personalized advertising.
The Company has the right to collect and process the information necessary to enable the display of personalized advertisements on the services, website and e-mail address provided by the Company. However, commercial advertising information (direct marketing information) is received only by users who have agreed to receive commercial advertising information (receive marketing information).
- To keep track of the content accessed by users in relation to the Services and online behavior
- To personalize ads in accordance with the user and provide targeted marketing and promotional offers
- To provide offers and information on services that the user may find interesting
5) The Company may analyze and classify all of the collected data for all of the aforementioned cases and purposes.
The Company has the right to collect and process the information necessary for the performance of the contract, the provision and maintenance of appropriate services and the creation of personalized advertisements. However, no personal data that the user has not agreed to provide will be used.
3. With whom does Vawraek share personal information?
The Company does not share personal information with which the user can be directly identified with a third party without the user's consent. However, in order to comply with applicable law, the Company may share personal information with third parties through an appropriate procedure when reasonably necessary to protect the important interests of the user or others, or to achieve the legitimate interests of the Company.
1) Other Users and the Public
- If the User publishes a post on the website dashboard, the post will be available to other users or the public.
- In the event that the User uses public chat within the game, the chat content will be viewed by other users.
- In the event that the User violates the User Agreement or is selected as an event winner, some game information such as the character name, clan name of the relevant user may be announced through the website and official community notifications.
2) If the user has given prior consent
- Before collecting or providing information, the user is informed about "to whom personal information is provided, what personal information is provided and for what reasons personal information is provided" and a procedure is implemented whereby the user's consent is obtained. If the user does not consent, personal information is not shared with a third party.
3) Partner Companies and Service Providers
4) Public and Investigative Organizations
- The Company may provide data to other companies and public organizations in accordance with legal procedures to prevent fraud and illegal activities.
- The Company may provide users' data to public organizations in accordance with legal procedures in order to comply with the law or to protect the company and company employees, other rights, property and security.
- The Company may provide users' data at the request of the investigating organization in accordance with the provisions set forth in the law or in accordance with the procedures and methods set forth in the law for investigative purposes.
5) Advertising Company and Social Media
- Facebook: https://www.facebook.com/about/privacy
- Google: https://policies.google.com/privacy
- Twitter: https://twitter.com/en/privacy
6) Delivery Company
- For the delivery of prizes such as event prizes, the address and contact information provided by the user may be shared with cooperating companies. This data is only used for delivery purposes.
7) Payment Service Company
- Where payment of fees is required in connection with the provision of services, user data may be provided to the company providing the payment service.
4. How long does Vawraek retain and dispose of personal information?
The Company retains and uses the personal information collected in accordance with the user's consent as long as the user's membership continues. When the purpose of collecting and using the collected personal information is reached (e.g. membership cancellation request, termination of the event, etc.), the relevant information is destroyed without delay. (However, personal information is kept for 15 days after the membership cancellation request to prevent unwanted membership cancellations due to reasons such as theft of personal information and to minimize damages such as payment theft.)
However, in accordance with the data-related laws of the Republic of South Korea, the following information is retained for the period specified for the relevant reasons and cannot be used for any other purpose.
1) Reason for Retaining Information According to Relevant Laws
Law on Confidentiality of Communications
- Entry logs: 3 months
Consumer Protection Law during Electronic Commerce
- Labeling and advertising records: 6 months
- Contract or withdrawal records: 5 years
- Records of payment and supply of goods: 5 years
- Records of consumer complaints and dispute resolution: 3 years
Basic National Tax Law, Corporate Tax Law
- Account book and proof of all transactions determined by tax law: 5 years
2) Other Reasons for Retention of Personal Information within the Scope of the Company's Internal Policy
The Company may retain personal information collected for events/promotions etc. for a maximum of 1 year. However, this period may vary depending on the event/promotion, and the period of collection and use of personal information specified separately in the event/promotion will take precedence.
In addition, the company has the right to retain the following information in order to limit Steam members from obtaining items more than once by re-registering after withdrawing their membership. (This information is not personally identifiable.)
- Steam member ID number, DLC item payment information
In principle, the Company destroys personal information without delay when personal information reaches the purpose of collection and use or when the period of storage and use is exceeded. The procedure and method of destruction of personal information is as follows.
The user's personal information is destroyed immediately after the purpose of collecting and using the relevant information has been achieved (at the end of the 15-day grace period in case of membership cancellation). However, it destroys it after keeping it for a certain period of time depending on the information protection reasons of the laws.
Personal information printed on paper (print, written documents, etc.) is shredded or incinerated. Personal information saved in electronic format is permanently deleted in such a way that it cannot be restored.
5. What precautions does Vawraek take when transferring personal information abroad?
Since the Company provides services worldwide, user information may be transferred to any country and different protection laws may apply depending on the country, regardless of the user's home country. The range of laws for data protection may not be narrower or stricter than the laws in the user's region, but the company takes appropriate safeguards to protect the user's personal information depending on the applicable laws.
6. How Vawraek Protects Personal Information
To ensure the security of personal information, the Company takes and implements the following technical, administrative and physical measures to prevent loss, theft, leakage, alteration and damage to users' personal information. However, although the company has fulfilled its obligation to protect personal information, the company cannot be held responsible for the leakage of personal information due to negligence caused by the user's carelessness, such as password management negligence, or due to an accident that the company cannot intervene in.
1) Technical Measures
- The Company encrypts and stores not only the items of personal information specified by applicable laws, but also additional items.
- The Company protects important data containing personal information by encrypting file and data transmission or using security functions such as file locking function.
- The Company always conducts audits to prevent leakage or damage to the user's personal information due to hacking or computer viruses. In addition, the Company regularly backs up personal information and protects it with various security devices such as Anti-Virus program and Firewall in order to be prepared for a possible situation.
- The Company takes the necessary measures to ensure the security of the database system, which is systematically structured to process personal information.
2) Administrative Measures
The Company limits the authorization to access the user's personal information to a minimum number of persons, and the minimum number includes the following
- The person who performs direct marketing, event, Player Support, delivery works with the user (including Dispatch and partner company employees)
- The person responsible for the duty to protect personal information, including the officer responsible for the protection of personal information
- A person whose processing of personal data is unavoidable due to his/her duty
- The Company regularly conducts trainings on obligations such as the protection of personal information for personnel processing personal information and companies receiving referrals.
- The Company establishes and manages a personal information processing policy in the department responsible for the protection of personal information. In addition, the company regularly checks whether the internal rules are being implemented, and if any problems are detected, the company does its best to resolve the problem quickly.
3) Physical Measures
- The Company maintains the personal information system in which it stores personal information in a physically separate location and has established and implemented an access procedure.
- The Company protects documents and auxiliary storage devices containing personal information in a secure location with locked devices.
7. What is the Information Collected Automatically (Cookies, etc.)?
It provides personalized services by analyzing the access frequency and visiting hours of members and non-members, tracking and determining the user's likes and interests, and determining the number of visits.
The Company and its analysis service providers use tracking technologies such as cookies, beacons, tags or scripts. These technologies are used to collect statistical information of users who use the company's website in general, such as trend analysis, website management and the user's use of the website. The Company may receive data in aggregate form using these technologies through analysis service providers.
2) How to Prevent Cookies from Being Saved?
In addition, the company may use various external web log analysis tools for advertising and analytics purposes and may allow online personalized advertising providers to collect behavioral data.
8. Are there any age restrictions for using the Service?
- The Company does not intentionally collect or solicit personal information from users defined by law as children (hereinafter referred to as "child users") or intentionally allow them to use the Services by sending interest-based promotions.
- However, if a child user consents to the User Agreement and becomes a member, he or she is deemed to have the consent of his or her legal representative.
9. How do I contact Vawraek?
The Company will assist the user in the fastest way possible if the user has any questions regarding the protection of his/her personal information or if he/she has a request for the solution of problems related to his/her personal information, including by contacting us via our e-mail address firstname.lastname@example.org.
In addition, users can report all complaints that arise regarding the protection of personal information while using the company's services via the e-mail address email@example.com. The Company will do its best to address and respond to all complaints as quickly as possible.