Last Updated: 21 June 2022

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 (“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.

If you register your interest in Avatar or the Avatar Closed Beta Test (if you are located in Canada or the Philippines) through the Website, we will collect your email address or phone number, IP address and operating system. We will collect your email address to let you know when Avatar is launched in your region. More Information.

We use your information to provide you with the latest news about Avatar or to send you a link through the Website to participate in the Avatar Closed Beta Test (if you are located in Canada or the Philippines). We do not share your information with any third parties, except where we need to in order to provide the Website or where we are instructed to by a court, authority or compelled by law. More Information.

We use some third parties to help us deliver the best possible experience (such as to send you a link to sign up for the Avatar Closed Beta Test). 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 Website, and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.

Our servers are located in Singapore and the United States. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore. More Information.

We generally retain your information for the lifetime of the Website, after which your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws. More Information.

Depending on where you are, 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. More Information.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us here.

Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. More Information.

Data Controller: Sixjoy Hong Kong Limited | Email: dpo@avatarreckoning.com

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information when you register your interest in the Avatar game or the Avatar Closed Beta Test (if you are located in Canada or the Philippines) through the Avatar website (“Website”) 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 details through the Website. By providing your details through the Website you are acknowledging our rules regarding your personal information as described in this Privacy Policy.
The Website has been developed by Sixjoy Hong Kong Limited (“we”, “us”, “our”).
For the purpose of data protection laws, the data controller of your personal information in relation to the Website is Sixjoy Hong Kong Limited. The registered address of Sixjoy Hong Kong Limited is Room 907, Wing Tuck Commercial Centre, 177-183 Wing Lok Street, Hong Kong.
Our data protection officer can be contacted at dpo@avatarreckoning.com.
Our representatives for data protection purposes in certain jurisdictions are as follows:

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 dpo@avatarreckoning.com.

Children must not use the Website for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).
By children, we mean users 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 in the table below.

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo@avatarreckoning.com and we will delete such information.

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Website. 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.

This section describes the different types of personal information we collect from you in connection with the Website and how we collect it. For users who live in the United Kingdom, the European Economic Area, Switzerland, Thailand, Brazil or Turkey (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

Our corporate group operates around the world. Pursuant to our contract with you to provide the Website, 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 the Website are located in Singapore and the United States.
In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore.
By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore and the United States.
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 Website, including to send you news about Avatar and to process data for analytics purposes to understand the use of the Website. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.
• Companies within our corporate group who process your personal information in order to operate the Website. All related group companies may only use your personal information in accordance with this Privacy Policy.
• Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:
enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
odetect, prevent or otherwise address security, fraud or technical issues; or
oprotect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (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.

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 implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Website or otherwise via the Internet; any transmission is at your own risk.

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

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.

Some jurisdictions’ laws grant specific rights to users of the Website which are set out in this section.
This section entitled “Your Rights” applies to users that are located in the Relevant Jurisdictions.
The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada, Argentina, India, Russia and the Kingdom of Saudi Arabia.
The sub-section entitled “Advertising” also apply to users that are located in Hong Kong, Macau, Japan, Malaysia, Singapore, Korea, Thailand, United States, Canada, Australia, New Zealand, Argentina, Brazil, Cambodia, Egypt, India, Indonesia, Laos, Maldives, Mexico, Morocco, Myanmar, Philippines, Russia, Sri Lanka, Taiwan, Turkey, UAE, Saudi Arabia and Vietnam.
You may have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at dpo@avatarreckoning.com. Access
You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us at dpo@avatarreckoning.com. PortabilityYou have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property). CorrectionYou have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo@avatarreckoning.com. ErasureIf there is any other personal information you believe we process that you would like us to erase, please contact us at dpo@avatarreckoning.com.
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 Website 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 OnlyYou have a right to require us to 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). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too. ObjectionYou have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at dpo@avatarreckoning.com.
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 at dpo@avatarreckoning.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. AnnouncementsWe 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 Website 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. AdvertisingYou may choose to stop receiving personalised advertising or marketing promotions from us when using Avatar by contacting us at dpo@avatarreckoning.com.

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo@avatarreckoning.com.
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 dpo@avatarreckoning.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 think we have infringed data protection laws.

If we make any material changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Website, 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.

AlgeriaBy using this Website, you give us your consent for the collection, storage, treatment and use of your personal information, and transfer of your personal information to a third party (local cloud providers to back up your data or our affiliates around the world to help us deliver the Website) located in Singapore and the United States (as described in the Privacy Policy) where it is manually and electronically treated.

ArgentinaYour rightsIf 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).

Data transfersWhile 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 us your personal information and by using the Website, 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.

AustraliaOverseas RecipientsWe 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.AccessYou have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo@avatarreckoning.com.CorrectionYou have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Website account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo@avatarreckoning.com.ChildrenIf you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Website.Transacting AnonymouslyWhere practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Website. 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 Website, including social media integration and in-Website purchases.Your RightsIf 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). Data TransfersWhile 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. BangladeshAgreementBy accepting this 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 this Privacy Policy. By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore and the United States. Age RestrictionIn order to use the Website, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts. BrazilThis section applies to users located in Brazil:Consent RevocationWhenever 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 dpo@avatarreckoning.com. This may affect our provision of the Website to you.Parental and Guardian ConsentIf you are under the age of 18, you should not use the Website for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.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. CaliforniaThis section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).Collection and Disclosure of Personal InformationOver the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:• Identifiers, such as email address, operating system and IP address. 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 activity information, such as your information regarding your use of the Website and other device information as described in the main Privacy Policy. This information is collected directly from you and your device. • Other information described in subdivision (e) of Section 1798.80, including information about your gender, nationality, or age. This information is collected directly from you in the context of being our consumer.We collect your personal information for the following purposes:• To provide you with the Website and inform you about when Avatar is launched in your region.• To improve our services, including the functionality of the Website. • To address and remediate technical issues and bugs.For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.
We disclose personal information to the following types of entities:• Other companies within our corporate group who process your personal information in order to operate the Website. • Other companies that provide services on our behalf in support of the Website and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.• Regulators, judicial authorities and law enforcement agencies• Entities that acquire all or substantially all of our business.

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.Rights under the CCPA:If you are a California resident, you have the right to:• Request we disclose to you free of charge the following information covering the 12 months preceding your request:
• othe categories of personal information about you that we collected; • othe categories of sources from which the personal information was collected;• othe purpose for collecting personal information about you; • othe 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 • othe specific pieces of personal information we collected about you;• Request we delete personal information we collected from you, unless CCPA recognises an exception; and • 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 CCPA. We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your RightsFirst, 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 at dpo@avatarreckoning.com.CanadaIf 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 at dpo@avatarreckoning.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.
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. ColombiaHow We Use Your Personal InformationFrom the entry into force of this Privacy Policy, at the time of the collection of your personal data, we will request your prior authorization, by informing you about the specific purposes of the processing of your personal data for which such consent is obtained under the Privacy Policy.
Your authorization may be expressed (i) by writing, (ii) orally or (iii) through unequivocal conducts that allow us to reasonably conclude that your authorization was 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.Your Rights
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 if you want to exercise any of these rights through our contact information in the section ‘Contact & Complaints’ of this Privacy Policy. Proceedings For The Exercise Of Your RightsQueries (rights to access): You can file queries regarding the processing of your personal data by us.
Claims (right to correction and erasure): You have the right to file claims in relation to the processing of your personal data by clearly describing the facts that give rise to your claim.EgyptThis Privacy Policy is provided in Arabic for users located in Egypt. In case of dispute, the Arabic version of this Privacy Policy shall prevail.
By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. If you do not consent to this Privacy Policy, you must not use the Website.
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 in which we have databases or affiliates, in particular Singapore and the United States
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.FranceYour RightsInstructions for the processing of your personal data after your deathYou 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 at dpo@avatarreckoning.com. 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 reject 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.IndiaAge RestrictionsParental consent is required for children under the age of 18 years to use the Website.
Sharing Of Your Sensitive Personal InformationWhere 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 the Sensitive Personal Information to the extent required by applicable laws.Withdrawal Of Consent 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 at dpo@avatarreckoning.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. IndonesiaConsentBy 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.Parental and Guardian ConsentIf you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Website.Data Subject RightsYou have the right to access your personal information stored in our Website from time to time in accordance with applicable data privacy laws and regulations in Indonesia.Data BreachIn the event we fail to maintain the confidentiality of your personal information in the Website, we will notify you through the contact information provided by you or via the Website, to the extent required by local laws and regulations.Data RetentionWe will retain your personal information in line with legal requirements. Notification to Amendment of this Privacy PolicyIf you fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen (14) days of the date the relevant amended version of this Privacy Policy is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy. However, you may stop using or accessing our Website by unsubscribing or ceasing your use of the Website at any time, if you cease to agree with the amended Privacy Policy.Data Accuracy and Third Party ConsentYou 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). JapanMinimum AgeIf you are under the age of 18, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Website.Consent to transfer to third partiesBy clicking “accept”, 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 where we have databases or affiliates and, in particular, to Singapore and the United States.Your RightsYou 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 at dpo@avatarreckoning.com. Kingdom of Saudi ArabiaYou 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. KuwaitYou represent that you are at least 21 years old, or 18 years old and have obtained parental/guardian consent and, therefore, legally capable of contracting under the applicable laws and regulations in 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 SARYou have the right not to provide your personal information. However, as a result, we may not be able to provide the Website to you. As a Macau SAR 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. MalaysiaParental and Guardian ConsentIf you are under the age of 18, please do not use the Website.
In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Website, 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.Your RightsRight 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 using the contact details provided above. However, this may affect our provision of the Website to you. ContactTo 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 • oTelephone: +603-22872388• oEmail: dpo@avatarreckoning.com

MexicoLanguageThis Privacy Policy is provided in Spanish for users located in Mexico. In case of dispute, the Spanish version of this Privacy Policy shall prevail.Age RestrictionsYou won’t be able to use the Website unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf).
Types of Personal Information We UseForData Transfer Consent clarification purposes, in section "The types of personal information we use” and section “How we use your personal information” you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations. Purposes of ProcessingSome of the purposes of processing stated above are for voluntary purposes, including to show you personalised recommendations and advertising. We may also use your personal data for the voluntary purpose of sending information to your email information that we may consider relevant to you. You may object the processing of your personal data for voluntary purposes as stated in the section “Your Rights” below.
Please, be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and to carry out the transfer of personal data detailed in section “How we store and share your personal information”. Data Transfer ConsentIn general, we do not require your consent to carry out the transfers detailed in section “How we store and share your personal information”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.
By using the Website and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section “Your Rights” below.Your RightsThe sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data, and “Advertising” included in Section “Your Rights” above also apply to users that are located in Mexico.
You also have the right to revoke the consent that you have provided us to process your personal data.
To exercise any of your rights, contact our Data Protection Officer at dpo@avatarreckoning.com.
To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our Data Protection Officer at dpo@avatarreckoning.com. CookiesThrough the use of cookies, we collect certain information related to your browsing and device, some of which may be considered personal data (detailed in the relevant sections above). You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, you should consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionalities of the Website may no longer be available to you. For more information about our use of cookies and how to disable them, please visit our Cookie policy.

MoroccoThe protection of your privacy is an important principle for us. We collect information for purposes strictly necessary for the proper use of the Website.
By accepting these conditions of use, you explicitly accept that your personal data may be subject to processing by the Website.
Kindly note:
• the identity of the Data Controller is Sixjoy Hong Kong Limited, email: dpo@avatarreckoning.com. • the purposes of the processing for which the data is intended are set out in the table in the section “How we use your personal information”.• recipients or categories of recipients are set out in the second paragraph of the section “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 the section “How we use your personal information” and the section “Your Rights” (sub-paragraph “Objection”).

New ZealandThis section applies to users located in New Zealand:
Overseas Recipients 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. AccessYou have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo@avatarreckoning.com.
CorrectionYou have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo@avatarreckoning.com.ChildrenIf you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Website.Your RightsIf 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). Data TransfersWhile 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.

PeruYou 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 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.
Upon your request, we will take necessary measures without delay in accordance with applicable laws such as 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.ContactTo 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. • Data Protection Team, responsible for the management and safety of your personal information• Contact: dpo@avatarreckoning.com

PhilippinesMinimum AgeYou must be at least 18 years of age to be able to use the Website.Your RightsYou 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 proc essed, 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 informat ion 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. Consent • collecting and processing your personal information as described in the section “How We Use Your Personal Information” above; • sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially 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 the section “How We Store and Share Your Personal Information” above.

QatarIf you are using the Website 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 KoreaHow We Store and Share Your Personal Information
Provision of personal information to third parties
We provide your personal information to third parties as described below:

Overseas Transfer of Personal Information We transfer personal information to third parties overseas as follows:

Data DestructionPersonal 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:

Your Rights 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.
Upon your request, we will take necessary measures without delay in accordance with applicable laws such as 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 InformationIn 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 the collection; • whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing; • 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 RepresentativePursuant 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: Tencent Korea Yuhan Hoesa • Address: 152 Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Korea • Telephone Number: +82-2-2185-0902 • Email: dpo@avatarreckoning.com ContactTo 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.
• Data Protection Department, responsible for the management and safety of your personal information • Telephone: +82-2-2185-0902 • Email: dpo@avatarreckoning.com

RussiaThe Website is not directed at Russian users or Russian market and, in particular, is not available in the Russian language. However, if you are using the Website in Russia, this section “Russia” applies to you. By using the Website you consent to:
• for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations, the processing of your information in accordance with this Privacy Policy; if legitimate interests, optimisation of the Website or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law); • the cross-border transfer of your information to any country where we have databases or affiliates, in particular Singapore and the United States; • for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this Privacy Policy; and • for the purposes of Federal Law “On Marketing/Advertising”, that we may share advertising/marketing communications with you, unless you have opted-out from such communications. We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Website after the notification.
As regards the representative for Russia, you can contact us at dpo@avatarreckoning.com. Please include the word “Russia” in the subject line of your email.

SingaporeBy clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular the United States.AccessYou have the right to access your personal information, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo@avatarreckoning.com.
CorrectionYou have the right to correct any of your personal information that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact dpo@avatarreckoning.com.
Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at dpo@avatarreckoning.com.

South AfricaYou 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 LankaBy clicking “accept”, you consent to the terms and conditions of the Privacy Policy and permit the collection, use and disclosure of your personal information. However, if you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Website.
Where you request to withdraw consent or, refrain from further processing of data or, erase or, rectify or, complete your personal information, we will provide you with our response to the request within 21 working days.

TaiwanWe do not knowingly collect or solicit personal information from anyone under the age of 7 or knowingly allow such persons to register on the Website platform. If you are under 7 years of age, please do not attempt to use or register for our Website or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using the Website. In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using the Website.

ThailandBy clicking “accept”, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the Website.
You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at dpo@avatarreckoning.com.
We will give you notice by email of any material changes to this Privacy Policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

TurkeyOur Data Controller Representative in Turkey for the purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations, Özdağıstanli Ekici Avukatlık Ortaklığı, can be contacted at tencent@iptech-legal.com. Please include the word “Turkey” in the subject line of your email.
You have legal rights, which are set forth in Article 11 of the 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:

UkraineBy 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 other than Ukraine, to the extent and for the purpose provided by this Privacy Policy.

United Arab EmiratesYou 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.

VietnamBy accepting this Privacy Policy, you expressly agree and authorise us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.
We maintain international standards and security practices for data protection. When your personal information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.
Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.
Your personal information, if required to be disclosed to the law enforcement agencies, public authorities or other judicial bodies and organisations, it will disclosed upon receipt of written request from such organisations. Your RightsYou have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.