Privacy Policy

Effective Date: June 15, 2022

1. Identification of Data Controller.

For the purposes of this privacy policy (“Privacy Policy”), the “Data Controller” is GameSpring CO., LTD. registered at 23, Gangnam-daero 84-gil, Gangnam-gu, Seoul, Republic of Korea. Subsequently, “We”, “Us” and “Our” refer to the Data Controller.

This Privacy Policy applies to usage of any of Our games, apps, products, services content, including but not limited to http://www.gamespring.co.kr/, http://www.dragonacecasino.com/, and/or other domains or websites operated by Us, hereafter referred to as our “Services”.

GameSpring respects your privacy and is committed to making Our practices regarding your data more transparent and fair. This Privacy Policy describes how We collect, store, use, and disclose your personal information (hereafter also referred to as “personal data”) when providing Our Services to you. Furthermore, this Privacy Policy also describes your rights and choices concerning your personal information.

If you do not want GameSpring to collect, store, use, or share information in the ways described in this Privacy Policy, you are prohibited from using any of Our Services.

2. The Information We Collect, How We Collect It, and the Legal Basis of it.

We need to collect and use certain data to provide the Services to you. While using Our Services, you may provide Us some of your personal information. We will store your information in Our systems for the exclusive purpose described in this Privacy Policy.

The legal basis for collecting and using the information depends on what the information is and the context in which We collect it.

Generally, We will normally process your personal information for a legitimate interest in efficiently fulfilling Our contractual and legal obligations, account management, management reporting, market review and analysis, promotion of Our Services, and business development. In some cases, the processing is necessary to perform Our contract with you (i.e., Our Terms of Service) or to fulfill legal obligations, or to protect your vital interests or those of another person (for example, another user).

Information You Provide To Us.

When you use Our Services, you may be asked to provide Us some or all of the following personal information:

Your first and last name;
Your email address;
Your nickname;
Your Facebook App ID;
Your device ID; and/or
Your encrypted password.

Additional information may be requested for the purposes of securing your account and/or improving Our services.

Furthermore, We may also collect the following non-personal information:

Age;
Gender;
Location;
Language;
IP address; and/or
Information about your hardware.

We may also allow you to create a public profile, which other users of Our Services may be able to see. Your public profile may include the following information:

Your profile photo;
Your game nickname;
Your country of residence; and/or
Details about your game statistics.

Information You Generate Using Our Services.

Additionally, when you use Our Services, We may collect information about the ways in which you use and interact with Our Services, such as when and for how long you play Our games, game features, and other players you interact with, purchase you make, progress or levels you achieve, and other gameplay activities.

Customer Support.

If you contact Our Customer Support team, We may collect and store the contact information you provide (this may include, but is not limited to, your name and your email address, information about your gameplay or activity on Our Services, your game ID, username, operating system, and Unique Device Identifier (UDID)). We may also store the communications you have with Our Customer Support team and any additional information in those communications in order to provide ongoing support and improve Our Services.

Use of Social Media.

If you access any of Our Services through Social Media (for example, Facebook or Twitter), We may receive certain information about you. The information We receive is determined by each particular platform and the consent that you have provided to them.

Please note, third party social networks are governed by their own privacy policies, terms, and end-user agreements, and We are not responsible for and have no control over the sharing practices or policies of the third parties that operate those sites. For additional information, contact Us at support@gamespring.co.kr.

It is your responsibility to review and understand the third-party’s terms of services and their privacy policy.

Payment Information.

When you use any of Our Services that are connected to a third-party application or platform, for example, Apple, Google, or Amazon, any monetary transaction “a purchase” that you make will be processed by that third-party provider. You may be subject to that third party’s terms of service and/or that third-party’s privacy policy.

We do not receive any of your financial information. However, We may receive non-financial information related to your transactions within Our Services, for example, your name, your approximate physical location, and the item or service that you purchased.

The information that We receive is dependent on which Service you are using and which third-party provider manages the transaction.

Our Terms of Service explain Our policies regarding charges, billing, third-party credit, and virtual currencies. For more information, refer to our Terms of Service.

Cookies and Other Automated Information Collection.

As described in Our Cookie Policy, We use cookies to recognize you and/or your device(s) on, off, and across different Services and devices. We may also allow our third-party service providers to use cookies and similar technologies in accordance with Our Cookie Policy. You may control or opt-out of the use of cookies and similar technologies by following the steps described in Our Cookie Policy.

3. How We Use Your Information.

We will use the information that you provide to Us for the specific purposes for which you provided that information, as stated at the time of collection. Hereunder are some of the ways in which We may use your information:

To optimize and enhance Our Services and users experience;
To create your account, which will allow Us to identify you while you are using Our Services;
To establish communication with you about the Services you’re using, including updates, new Services, and promotional offers;
To provide technical support and respond to your inquiries;
To protect the safety and well-being of Our users;
To protect Our rights and property in connection with Our Services;
To avert any fraud or potentially illegal activities while you are using Our Services;
To manage rewards, surveys, contests, and/or other promotional activities;
To conduct research;
To enable user-to-user communication;
To manage and deliver contextual and behavioral advertising; and/or
To comply with Our legal obligations, resolve any disputes We may have with you or other users, and to enforce Our agreements with third parties.

4. How We Share Your Information.

We will not share the personal information We collect from you through Our Services with third parties, except as described in this Privacy Policy. We may share your information with third parties or allow third parties to collect this information from Our Services in the following circumstances:

To Other Users.

As mentioned above, your public profile (such as profile photo, nickname, country, and game statistics) will be able to be seen by other users of Our Services.

To Third-Party Advertising, Including Behavioral Advertising and Analytics.

We may share some of your data, such as your advertising ID, with advertisers for the purpose of tailoring the advertisement you see when you use Our Services. We use advertising to be able to offer some of Our Services for free.

These advertisements may include, without limitation, video ads, banner ads, and “offerwalls” in which third-party advertisers may provide virtual currency or other in-game items to users in exchange for completing a task.

The offers displayed within Our Services are created and hosted by third-party providers, not by GameSpring.

To enable advertisers, ad networks, and offer wall providers to serve you with more relevant ads, they may collect, or We may collect and share with them, the following types of information when you use Our Services:

Performance data (like the number of clicks on an advertisement);
Certain technical information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);
A unique identifier, such as player ID or social network ID;
Other contextual data about your gameplay (like your level and session length).

In addition to serving you with relevant ads, the information collected may be used to:

Measure how effective ads are:
Offer you targeted advertising (both on and off Our Services) in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as interest-based advertising or behavioral advertising); and/or undertake web analytics to analyze traffic and other player activity to improve your experience.

Ad networks may collect this data through the use of cookies and other similar tracking technologies, and they may use a single tracking technology or multiple tracking technologies at the same time.

After clicking on a third-party advertisement or offer, you may no longer be on a website/application/service hosted by Us. We are not responsible for the privacy practices or the content of those third-party services.

Activities related to third-party advertisements within Our Services are subject to the terms of those third-party companies’ privacy policies. We cannot guarantee that other third-party companies’ privacy policies will have the same terms and conditions as Our Privacy Policy. In the use of third-party provided services, such as in-game advertising and purchasing, it is your responsibility to review and understand all relevant policies. You may review applicable third party privacy policies here.

To Third-Party Service Providers.

GameSpring uses third-party companies to perform its services, like processing payments, analyzing data, optimizing gameplay, email delivery, hosting services, managing, and delivering contextual and tailored advertisements. We may share your information with third-party companies who perform services on Our behalf, like analytics, analysis, hosting services, customer service, marketing, and advertising optimization. We may also share your data with our third-party partners who assist us in delivering and optimizing our Services, such as our platform partners (Apple, Google, Facebook, etc.). Where We share your data with third-party service providers and partners, We make every effort to ensure that there are appropriate agreements in place to protect your information.

About our Third-Party Data Controllers and Processors.

GameSpring’s Partner List includes a list of trusted third parties companies with which We work directly or indirectly, and which may receive your personal data and further process that data according to their policies. We encourage you to review our partners' privacy policies to ensure that you understand their treatment of personal data that they may process.

From time to time, We may add new partners to this list or remove partners with which We no longer share information. Please be aware that when We share your data with third-party service providers and partners, We do so in adherence to our policy of making every effort to ensure that there are appropriate agreements in place to protect your information.

List of third party data controllers and processors.*

*Please note that We may not share your data with all of Our partners.

How Can You Turn Off Personalized Ads?

You are always free to opt-out from the future collection of your information by GameSpring in accordance with this Privacy Policy by choosing not to use Our Services.

In addition, you can take the following steps to control the collection of your information:

iOS

If you are using an iOS device, you can find the official guide for opting out from Apple here.

Android

Open the “Settings” application of your Android device and select the “Google” menu item. Depending on your device, this option may not be visible on the main menu, but you may use the search function at the top of the Settings menu to find it. From there, select the “Ads” sub-item and activate the option “Opt out of Ads Personalization” to prevent the creation of profiles and the display of personalized advertising. You can delete the advertising ID on the same menu at any time (“Reset advertising ID”), and then a new ID will be created and will not be merged with the previously collected data.

Please note that if you reset your advertising ID or opt-out of interest-based advertising, you may still see advertisements in Our Services, but those ads will not be targeted based on the identifiers mentioned above. For example, such ads may be instead based on contexts, such as your progress and actions in Our Services, or your language preferences. Please be aware that such actions may result in a less enjoyable user experience.

5. How Long Do We Store Your Personal Information.

The period for which We will retain your personal information is dependent on the reason for which it has been collected. We will never retain your personal information for longer than is required to provide you with Our Services or to meet our legal obligations or to exercise, defend and protect Our rights, whichever is longest.

The personal information that associates you with an account and/or any of Our Services will be retained for at least as long as you have an active account with Us.

In the event you ask Us to delete or close your account, We will take all reasonable measures to delete your personal information from Our records. However, in the case that you have opted and agreed to submit optional content to Our Services, We may be unable to remove that content in its entirety. Additionally, We may retain select information where We need and have the right to do so, such as for legal and/or accounting purposes. Such cases may include but are not limited to, information related to your payments or customer service inquiries. We may also keep information in order to exercise, defend, or establish Our rights.

For more information on deleting or closing your account, please refer to article “9. Your Rights”.

6. Security Measures for Your Information.

We implement all recommended industry practices in security measures to protect your personal information. We take all reasonable actions to prevent any unauthorized access or use of your personal information.

However, please be aware that regardless of any security measure used, We cannot and do not guarantee that hacking, data loss, unauthorized access, or any other type of breach will never occur. Any transmission of information is done at your own risk.

7. International Data Transfers.

GameSpring operates globally, and Our Services are global by nature. Your personal information collected via and/or by Us may be stored anywhere in the world and may be transferred to, and processed in, countries other than the country of which you are a resident. These countries may have data protection laws that are different from the laws of your country.

When We transfer your personal information internationally, We take steps to ensure that adequate safeguards are in place to protect your personal information, and it is treated securely, lawfully, and in accordance with this Privacy Policy.

8. Policy Regarding Children.

The safety and privacy of children are of paramount importance to Us. Our Services are not intended for nor directed at users under the age of 17 (the “Children”). We will never knowingly collect or solicit information from any Children. Children are prohibited from using any of Our Services.

Parents or guardians that believe that We do hold information about their Children should contact Us at privacy@gamespring.co.kr.

9. Your Rights.

Your rights include, but are not limited to:

Requesting access to your personal information;
Updating, correcting, or erasing your personal information;
Requesting the deletion of all of your personal information;
Consenting to the processing of your personal information, where applicable;

To exercise any of your rights, please submit a request to privacy@gamespring.co.kr. You may be required to provide particular forms of proof of identity in order that We do not disclose personal data to those that are not entitled to it.

When you request the elimination of your personal information, We will only retain information that is subject to the terms described in Section “5. How Long Do We Store Your Personal Information.”

10. Changes to the Privacy Policy.

From time to time, it may be necessary for Us to amend Our Privacy Policy. We will post any changes to Our websites, and We will update the date at the top of the Privacy Policy.

The amended Privacy Policy will be effective upon posting on any of Our Services.

We highly recommend you to visit Our websites often to review Our Privacy Policy.

If you continue to use Our Services following an amendment to Our Privacy Policy, that usage constitutes an agreement to and acceptance of the terms of that revised Privacy Policy.

11. Compliance with the General Data Protection Regulation (GDPR).

If you are a user using Our Services in the European Union or the European Economic Area, please read carefully the terms and conditions in this Section.

We strive for strict compliance with the applicable terms and conditions in the European Union’s General Data Protection Regulation (hereinafter “GDPR”).

Our definition of Personal Data (hereafter the “Personal Data”) found in this section is in concordance to the definition contained in Article 4 of the GDPR. We will process your Personal Data in accordance with the applicable terms of the GDPR.

We will collect your Personal Data only with the purpose of providing Our Services, as described in Section “3. How We Use Your Information,” Section “4. How We Share Your Information,” and in this Privacy Policy. Once achieving the purpose of the collection of the Personal Data, We will use all reasonable effort to immediately and promptly delete all your Personal Data.

As set out in the GDPR, the requests you can make to Us can include:

The deletion of your Personal Data;
The limitation of the usage of your Personal Data;
The correction of your Personal Data; or
Any other actions allowed to you under the terms of the GDPR.

Upon your request, We will promptly respond to your inquiry to the best of Our ability in accordance with the applicable provisions in the GDPR.

For more information about the personal data We process, or if you wish to exercise any of your rights, please send Us a request by email at privacy@gamespring.co.kr.

12. Notice to California Residents.

This part of the Privacy Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, “CCPA“). Strictly for the purpose of this part of the Privacy Policy, the term "Personal Information" shall be as defined in the CCPA. This Notice to California Residents only applies to individual residents of the State of California in the United States of America.

Collection and Use of Personal Information

When We use the term "personal information" in this Notice, We mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer.

In the last 12 months, We may have collected the following about consumers for the following purposes.

Category of Personal Data Collected	Personal Data Collected (Examples)	Source of Personal Information	Categories of service providers to whom Personal Data was disclosed	Business Purpose for Collection
Identifiers	Name, username, email address, social media identifier, IP address, advertising ID, device and operating system information.	- Our players. - Our player’s devices. - Social networks. - Third parties.	- Customer services vendors. - Advertising networks. - Social media services. - Data analytics vendors. - Quality assurance vendors. - Cloud storage providers. - Service providers. - App distribution platforms.	- Operate Our business and provide Our Services. - Product development/improvement. - Customer service. - Detecting/Protecting against security events. - Internal analytics and reporting. - Internal research. - Game mechanics or functionality. - Facilitate player’s social interaction. - Maintaining and enhancing service, debugging. - Advertising and direct marketing. - Detecting/Protecting against security events, preventing fraud and abuse of Our policies. - User acquisition. - Compliance purpose and meeting legal/regulatory requirements.
Personal Data Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))	Name.
Commercial Information	Transaction information, purchase history. This does not include any payment information, which is collected directly by the mobile app distribution platform.
Protected classification characteristics	Age, gender.
Internet or other electronic network activity information	Interaction with Our Services.
Geolocation Data	Location.
Inferences drawn from the above.	N/A.

Online Advertising

We allow certain third-party advertising partners to collect the categories of personal information identified above (please see the table), for online advertising purposes.

These ad networks, social media companies, and other third-party businesses may collect personal information directly from a browser or device through cookies or similar tracking technologies. When a consumer visits or interacts with Our Services, these third parties may collect personal information and use your personal information to:

Serve relevant ads on Our Services;
To personalize content; and
To perform other advertising-related services such as reporting, attribution, analytics, and market research.

These third parties may use this personal information for their own commercial purposes in accordance with their own privacy policies, which may include providing this information to additional third-parties, including other advertising networks.

Please see Our Cookie Policy for more information about how third-parties use cookies and related technologies to automatically collect information on Our Services and the rights you may have in relation to those practices.

Please review Our partners' privacy policies to ensure that you understand their treatment of your personal data that they may process.

List of third party data controllers and processors.*

*Please note that We may not share your data with all of Our partners.

Selling Personal Information

WE DO NOT "SELL" PERSONAL DATA OF OUR USERS AS MOST PEOPLE WOULD TYPICALLY UNDERSTAND THAT TERM. However, as mentioned previously, We do allow certain third-party advertising partners to collect information about consumers through Our games for purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for ad fraud detection and reporting. In order to serve you personalized ads, We may share your resettable identifiers provided by your mobile device’s operating system with Our selected partners. Typical advertising IDs are ADID (Android) and IDFA (Apple). These mobile advertising IDs allow developers and marketers to track activity for advertising purposes and enhance the personalization of ads. You may reset these identifiers from within your mobile device or limit ad tracking for your mobile device, as mentioned in this Privacy Policy.

Your California Privacy Rights

Your rights include, but are not limited to:

Right to know	You have the right to request any or all of the following information relating to the personal information We have collected about you or disclosed in the last 12 months, upon verification of your identity: - The specific pieces of personal information We have collected about you. - The categories of personal information We have collected from you. - The categories of sources from which the personal information is collected. - Our business or commercial purpose for collecting personal information. - The categories of third parties with whom We share personal information, if any.
Right to deletion	You have the right to request the deletion of personal information that We have collected from you, subject to certain exceptions.
Right to Non-Discrimination	You have the right not to receive a discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits Our ability to process personal information (such as in the case of a deletion request), We might no longer be able to provide you Our Services or engage with you in the same manner.
Right to designate an authorized agent to submit CCPA requests on your behalf	You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, you need to provide the authorized agent written permission, and the agent will need to submit to Us proof that they have been authorized by you.
The Right to Opt-Out of Personal Information Sales	You have the right to direct Us not to “sell” personal information We have collected about you to third parties.

How to Exercise Your California Privacy Rights

To exercise any of your rights, please submit a request by:

Email to privacy@gamespring.co.kr with the subject line "CCPA Rights Request."

You may be required to provide particular forms of proof of identity in order that We do not disclose personal data to those that are not entitled to it.

To exercise your deletion rights, please refer to article “9. Your Rights” of this Privacy Policy and follow the instructions provided.

Note that GameSpring does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.

13. Contact Us.

If you have any comments, questions or concerns regarding your privacy or this Privacy Policy, please send us a message at privacy@gamespring.co.kr.

For all other matters, please contact GameSpring through support@gamespring.co.kr or by physical mail to GAMESPRING CO., LTD., 23, Gangnam-daero 84-gil, Gangnam-gu, Seoul, Republic of Korea.