Welcome to the Avatar:Reckoning Website and Closed Beta Test (CBT)!

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 Closed Beta Test (if you are located in the Philippines) (“CBT”) through the Avatar:Reckoning website (“Website”) or participate in the CBT, 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 or participate in the CBT. By providing your details through the Website and participating in the CBT you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

The Website and CBT have 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 and CBT for Avatar:Reckoning 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.

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.

1. Cookies

We use cookies and other similar technologies (“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.

2. Children

Children must not participate in the Avatar:Reckoning CBT or use the Website for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old in the Philippines.

Other than as provided above, 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 lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo@avatarreckoning.com.

3. How We Process Your Personal Information

This section describes the different types of personal information we collect from you and how we collect it. The following is a high-level summary of the types of personal information we use and provides more detail on the types of personal information we collect from you, and why.

Personal Information	Use
Website
Website (for CBT registration): If you are located in the Philippines: Email address, operating system, IP address (to determine your region), device information, gaming experiences, google analytics cookies	We use this information to send you an invitation link to the Avatar: Reckoning CBT and send you updates for future in-game promotional events.
Website (to receive updates about Avatar: Reckoning): Email address, operating system, IP address (to determine your region)	We use this information to provide you with information, news and updates about when Avatar: Reckoning will be launched or available in your region. We collect this information with your consent.
Google Analytics via Firebase: Default Firebase implementation collects: User device dimensions and in-app events such as number of users and sessions, session duration, operating systems, device models, geography, first launches, app opens, app updates, in-app purchases Firebase collects the following device dimensions: Age, app store, app version, country, device brand, device category, device model, first open time, gender, interests, language, new/established, OS version. Analytics also generates and assigns an app-instance ID to each instance of an app Firebase automatically collects the following in-app events: including advertising analytics such as ad clicks, ad exposure, ad impression, ad query, ad exposure, application analytics such as app usage, app clearance, app crashes, app removal, app payment analytics, app update and use analytics, website usage analytics, such as web clicks, browser downloads, notification, video progress, search analytics	We use this information for analytics purposes.
CBT Data
Guest log in information: Open ID	We use this information to create your account for the CBT in accordance with your request.
Account registration information (social media accounts) if you choose to log in via your social media account: · Facebook: Facebook ID, name, profile picture, user token and Open ID · Twitter: User ID, nickname, profile picture, user token and Open ID · Kakao: User ID, nickname, profile picture, user token and Open ID · Discord: User ID, nickname, profile picture, user token and Open ID · Line: User ID, nickname, profile picture, user token and Open ID · Google: User ID, nickname, profile picture, user token and Open ID · Apple: Apple ID, nickname, profile picture, user token and Open ID	We use this information to create your account for the CBT in accordance with your request.
Friends list: · Facebook / Garena friends: Your friends’ social media user Open ID, nicknames and profile pictures from your social media profile · Custom account friends: uid, token, username	We use this information to connect you with friends in the CBT.
Notifications and announcements: Open ID	We use this information to provide you with in-game announcements and notifications about the CBT.
Game server navigation: Open ID	We use this information to allow you to select a game server (the Philippines).
Compliance services: Open ID, token, region, username, email address	We use this information to ensure the security of the CBT and to verify your age / parental or guardian consent.
Email delivery service: Email address	We use this information to send you email notifications.
Country location: Your IP address (not stored)	We use this information to determine your region and assign a server to you. This is information is not stored by us.
Gameplay reports, performance, statistics and analysis: · User region: country, province, city, carrier ID, region, IP address · Device information: application version, application id, battery information, WiFi strength, available space, network type, OS version, OS name, carrier, country code, device language, device resolution, brand, manufacturer, device model, RAM, ROM and CPU information, GPU information, game frame information, mobile signal strength, network round trip time, network bytes received/sent, login/pay step event information, XWID	We use this information for analytics purposes to understand the quality of service that players experience so that we can better optimize the performance of our servers and customers.
User acquisition data via third-party SDKs (Appsflyer): Technical Information: Browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier Technical Identifiers: User agent, (identifier for advertisers), Android ID, Google Advertiser ID and Open ID Engagement Information: Clicks on ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, the webpages website visited, the URL from the referring website, downloads and installations of applications and other interactions	We use this information for user acquisition purposes.
Data analytics and profiling (Firebase): Default Firebase implementation collects: User device dimensions and in-app events such as number of users and sessions, session duration, operating systems, device models, geography, first launches, app opens, app updates, in-app purchases Firebase collects the following device dimensions: Age, app store, app version, country, device brand, device category, device model, first open time, gender, interests, language, new/established, OS version Analytics also generates and assigns an app-instance ID to each instance of an app Firebase automatically collects the following in-app events: including advertising analytics such as ad clicks, ad exposure, ad impression, ad query, ad exposure, application analytics such as app usage, app clearance, app crashes, app removal, app payment analytics, app update and use analytics, website usage analytics, such as web clicks, browser downloads, notification, video progress, search analytics ADID	We use this information for user acquisition purposes. We use the Firebase Instance ID to increase in-game rates of new users through Google platforms in our games.
Data analytics and profiling (Facebook): Contact Information: names, email addresses, and phone numbers, used for matching purposes only Event Data: information, such as site visits, app installations, products purchase, information collected and transferred when people access a website or app with Facebook Login or Social Plugins (e.g. the Like button), information created when an individual interacts with our platform via Facebook Login, Social Plugins Hashed Data: including personal data such as email addresses and phone numbers	We use this information for user acquisition purposes.
Customer Service (Game Data): Channel ID, Open ID, game ID, operatng system, area_id, role_id, game_server_id, zone_id, username Character ID, level of character, player's VIP level, player's remaining balance, account status, name of the Game, account binding status, registration time, latest login time, player type	We use this information to provide you with customer support.
Customer Service (Chat Data): Robotic sessions: Number of bot sessions served (person), number of bot resolutions (tickets), number of bot-to-man sessions (tickets), number of customer collection sessions (tickets), number of customer collection interruptions (tickets), number of unrecognized sessions (tickets), average number of interactions Manual sessions: Number of person sessions (tickets), number of person sessions (person), number of processed sessions (tickets), number of unprocessed sessions (tickets), number of sessions automatically closed after timeout (tickets), number of users who repeatedly raised orders twice (person), number of rejected orders (tickets), number of work orders created (tickets), number of transferred sessions (tickets), average length of first response, average length of response timeout sessions, average length of processing (hours), number of sessions processed per person (tickets/day) Chat History: Customer chat history (content in written form), customer information collection: Email address, customized information	We use this information to provide you with customer support.
Customer service (user behaviour): Home page visit PV (times), Home page visit UV (times), Search PV (times), Search UV (times), Search into AI (times), Search into FAQ (times), FAQ PV (times), FAQUV (times), FAQ participation (times), FAQ likes (times), FAQ stepping (times), Home page customer service clicks (times), human sessions (times), bot sessions (times)	We use this information to understand users’ actions within the FAQ page.
Customer service (device information): application identifier, application version, application name, OS version, platform, country code, language, SDK version, carrier, network type, device model, battery level, battery status, total space phone, free space phone, capacity, custom parameters	We use this information to provide you with customer support.
XWID: Your XWID, which is generated by us	We use this information for to verify guest login, debugging, and count the number of devices.
Data Analytics/Report: Firebase Instance ID and Open ID (via AppsFlyer）	We use this information to analyze users, optimize ads and user acquisition.
Data monitoring: error code, error message, SDK name, SDK version, request url, response body, seq_id, stage, log data	We use this information to perform game stability monitoring, and fix the problems detected.
Data analytics (user acquisition): Epic's Open ID, PSN ID, time zone, resolution, IP address, language	We use this information to analyze the user acquisition process, to better understand where all users who downloaded the game originated from.
Security (BUGLY): Device information: device name, device model, phone memory, CPU usage rate, CPU model, device system version, device brand, device manufacturer, ROM, RAM, device language, CPU architecture, whether root, remaining external SD card space, remaining memory, whether it is running in the simulator, running process information, APN, system time, battery status Other: Process name, Network Type, Application version, Application package name, SDK version, SDK information / user information version number / application information name and version number, buried data reporting	We use this information to help resolve crash issues and ensure the security of the CBT.
Account deletion information: Open ID, email address, region	We use this information to allow you to delete your account.
Security: game account, system version, network type, brand, CPU architecture, ROM unique identifier, device screen resolution, system boot time, country code and language, remaining memory, remaining built-in and external SD card space, whether Root, whether it is running in the simulator, installed APK information, running process information, file name list under SD card application cache directory, application package name, process name, application version, startup time, host file, in-game screen, whether it has been jail broken, whether external file has detection, application package name, application version, startup time, in-game screen, process name, host file, in-game screen	We use this information to ensure the security of the CBT, to detect and prevent cheating behaviour and to check for domain hijacking,
Survey information (optional): Gender, age or age range, country or region of residency, income information, education information, phone number, email address, nickname, any other content you choose to provide as part of the survey response If you choose to participate in a survey, we will automatically collect your User ID and Open ID	We use this information with your consent to better understand our users and to improve the CBT.
Text chat data (public lobby chat and private message chat): Open ID, role ID, text chat Please note that public lobby text chat is not retained by our servers.	We use this information to facilitate your communications with other users.
Voice chat data: Voice chat messages, device information (operating system, manufacturer, RAM, system time, device model, device name, CPU model, network type, IP address), log information (Open ID, room ID, SDK version, GME chat room status, packet loss rate and other log specific code) Please note that voice chat messages are not retained by our servers.	We use this information to facilitate your communications with other users.
Live translation into different languages: Identity information: OpenID System time Other: SDK version Network Type，Region ID， original audio language, target audio language, target text language	We use this information to facilitate your communications with other users.
In-game events via Pandora: Identity information: role ID, open ID, area district ID, partition district ID, platform ID , level, language, nation ID, belonging ID (Both nation ID and belonging refer to the country/region of the users)	We use this information to identify users’ account which would be relevant for the in-game events to be launched, to track users’ activity and for service monitoring.
Payment-in-app: Identity information: Open ID, role ID, country Device information: Device model, CPU model) Other information: country currency, SDK version, application version, network type,), amount of purchases)	We use this information in order to process any in-app payments.
Payment information (Midasbuy): Items purchased and their cost, the time, date and currency of the purchase, order ID, open ID, player ID, country, game account balance and purchase history	We use this information to enable you to use the payment function in our products and services via Midasbuy.
General customer support information: General information: your zone ID, platform ID, role ID, role icon, language type, Open ID, screen size, scene ID, area ID, app ID, country ID, channel ID, Information collected via international SDK: encode parameter, game ID, operating system, timestamp, SDK version, sequence, Game data query: game account information (such as registered username, social account, mobile phone, registration time, VIP level); game character information (such as role name, role ID, game duration, historical record); in-game data (such as items, currency, penalties, logins, activities, recharge, purchases, in-game friend relationships, game match data) Information for users with guest log-in to find their account: device information (such as device ID and IP address); and information provided by users (login channel, iOS or Android, name of role, device model, friends often gamed together with, time of registration, time of last log-in, time of last top-up, frequently used heros, previously used nicknames, highest ranking ever achieved, frequently playtime (i.e. time in the day) in the past 3 months (range given not exceeding 4 hours), last purchased skin, last purchased hero, email address, email verification code)	We use this information to improve our services and provide troubleshooting, such as addressing and remediating technical issues and bugs.

4. How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide the Website and CBT, 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 and CBT 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 and CBT, including to send you a link to allow you to sign up to the CBT for Avatar:Reckoning, to operate the CBT for Avatar:Reckoning, to process data for analytics purposes to understand the use of the Website and CBT, and improve gameplay. 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 CBT and conduct surveys for us. 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;
detect, prevent or otherwise address security, fraud or technical issues; or
protect 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.

5. The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the CBT or otherwise via the Internet; any transmission is at your own risk.

6. Data Retention

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.

Personal Information	Retention Policy
Website
Website (for CBT registration) Website (to receive updates about Avatar:Reckoning)	Email will be stored for one year after CBT is completed. Other data will be stored for the lifetime of the CBT (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Google Analytics	14 months before automatic deletion.
CBT
Guest log in Account registration information (social media accounts) Friends lists · Facebook/Garena friends · Custom account friends Notifications and announcements Game server navigation Compliance service Email delivery service Data analytics and profiling (Appsflyer) Data analytics and profiling (Firebase) Data analytics and profiling (Facebook) Customer Service: · Chat data · User behaviour · Device information XWID Data Analytics/Report Data monitoring Data analytics user acquisition Security data Payment information (in-app) Payment information (Midasbuy) Customer support information	Stored for the lifetime of the CBT (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Analytics service	7 days.
Customer Service (Game Data)	Stored temporarily for the purposes of access by customer service and deleted thereafter.
Security (BUGLY)	3 months.
Account deletion information	Data wil be retained for 30 days during the cool down period.
Survey information	1 year.
Text Chat Data (public lobby chat)	Text chat: Not stored. Log: Automatically deleted after 30 days, or within 30 days of a user’s deletion request.
Text Chat Data (private message chat)	Text chat: Stored for up to 14 days until the receiver reads the message. Log: Automatically deleted after 30 days, or within 30 days of a user’s deletion request.
Voice Chat Data (offline voice data only)	Voice chat messages: Not stored. Other voice chat data: Automatically deleted after 90 days or within 30 days of a user’s deletion request (whichever is earlier).
In-game events via Pandora	Automatically deleted after 7 days.

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.

7. Your Rights

You may have 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. Please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

Please note that we may refuse to comply with a request in certain circumstances where an exception exists under local law. When handling a request, we will check the identity of the requester to ensure that he/she is the person legally entitled to make the request.

To exercise any of your rights, please contact us at dpo@avatarreckoning.com.

8. Advertising

You may choose to stop receiving personalised advertising or marketing promotions from us when using Avatar:Reckoning by contacting us at dpo@avatarreckoning.com.

9. Contact

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.

10. Changes

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.

11. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

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

Philippines

You 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 processed, 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 information 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.

By consenting to this Privacy Policy, you consent to us:

· collecting and processing your personal information as described in Section 3 (How We Process Your Personal Information);

· 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 Section 4 (How We Store and Share Your Personal Information).