1. What type of information does 2NDLifeGames collect?

The company collects the following personal information when you sign up on our official website, use provided services (including mobile services), edit personal information, or submit inquiries via phone call, fax, or through customer support, as well as when partners provide and collect your information using a data collection tool.

1) Information provided by you

① Information provided during 2NDLifeGames account creation.
- Email address (account name), password, name and region

2) Data created while using our Services.

The company collects the following data that is created while you use our services with or without an account.
- Game progress data
- Chat records, IP address, PC information (e.g.: CPU, RAM, graphic card, vRAM, etc.)
- Gameplay data, interactions with other players while using our services, and all data related to the use of our Services
- Error information, MAC address
- Game screenshot (for game client errors)
- The information collected through cookies and related technology
- Web browser information, location information
- Data required to verify payment

2. Why does 2NDLifeGames collect information?
The company collects information for the following reasons.

1) We process the necessary data to provide services.

The Company collects information to provide services to you on your contractual relationship with us.
- To allow you to make an account and allow us to provide you services;
- To access our services;
- To provide products and services requested by you;
- To provide information about the products and services you request;
- To settle payments for purchases and paid services;

2) The company collects information to provide appropriate services.

The company collects the following information out of legitimate interest as the information is used:
- To improve and develop the services provided by the company;
- To improve and develop optimization of services and overall game experience;
- To update and develop player profiles;
- To set and manage registered account;
- To provide software updates;
- To maintain settings and provide content;
- To reply and provide support to submitted opinions or inquiries;
- To provide notices on changes made to Terms of Service, service errors, updates, security warnings, support, etc.;
- To create events and promotion programs for customers;
- To send event and promotion gifts

3) The company processes relevant data to provide safe and fair services.

The company has legitimate interest in collecting and processing the data necessary to accomplish the following purposes in order to keep your services safe and fair. Please see our Terms of Services for legal usage policies:
- To prevent abusive and unauthorized use of malicious users;
- To provide services to protect personal information;
- To allow quality game experience across multiple devices;
- To allow appropriate automatic or manual chatting;
- To find bugs, errors, and provide solutions;

4) The company processes necessary data to create targeted advertisements.

The company has legitimate interest in collecting and processing the data necessary to establish targeted advertisements on our services, other websites, and emails. However, commercial advertisements (direct marketing information) will only be sent to users who have agreed to receiving commercial advertisements (receiving marketing information).
- To track content accessed by users in relation to services and online behaviors;
- To customize advertisements and offer targeted marketing and promotions;
- To recommend or suggest information on services users may find interesting

5) For all the aforementioned cases and purposes, the Company may analyze and classify the entirety of the collected data.

The Company may have legitimate interest when collecting and processing data necessary to meet contracts, provide and retain appropriate services, and set up targeted advertisements. However, any personal data users have not agreed to provide will not be used.

3. Who does 2NDLifeGames share your information with?

The company does not share identifiable personal information with a third party without the consent of the relevant user. When requesting consent from a user, the company will provide information on the subject receiving the data, the purpose, and the type of data shared.

1) Other players and users

- If you post on the forums, it will be displayed for the public to see.
- If you chat using our services, it will be displayed for other players.
- In the event you violate the Terms of Service or Operating Policies, or win an event, parts of your in-game information (character name, guild name, ...) may be displayed on the website or forums for the public to see.

2) In the event the user consented in advance

- Before collecting or providing information, the user shall be notified of to whom the information will be provided, which information will be provided, and the reason for providing the information. The Company will go through the procedure to obtain consent, but if the user does not agree, it will not be provided to a third party.

3) Payment service company

- If deemed necessary for settlement of charges based on service provision, the user’s data may be provided to the payment service company.

3. Who does 2NDLifeGames share your information with?

The company does not share identifiable personal information with a third party without the consent of the relevant user. When requesting consent from a user, the company will provide information on the subject receiving the data, the purpose, and the type of data shared.

1) Other players and users

- If you post on the forums, it will be displayed for the public to see.
- If you chat using our services, it will be displayed for other players.
- In the event you violate the Terms of Service or Operating Policies, or win an event, parts of your in-game name, character name, and guild name may be displayed on the website or forums for the public to see.

2) In the event the user consented in advance

- Before collecting or providing information, the user shall be notified of to whom the information will be provided, which information will be provided, and the reason for providing the information. The Company will go through the procedure to obtain consent, but if the user does not agree, it will not be provided to a third party.

3) Partners and service providers

- The Company may provide user information to its vendors, consultants, marketing partners, research firms and other service providers or business partners. The information will be provided according to the clauses of this privacy policy.

4) Advertising companies and social media

- The company shares your information with advertising companies and social media (Facebook, Google, Twitter). Relevant third parties will have access to your information in accordance with the Privacy Policy to use tools that interact with social media, in-game advertising, and other operations of third-party companies. For more detail on how these third-party companies handle your information, please refer to the relevant third-party company’s Privacy Policy.

5) Payment service company

- If deemed necessary for settlement of charges based on service provision, the user’s data may be provided to the payment service company.

4. How long does 2NDLifeGames retain the information and how is it deleted?

The Company maintains and uses the collected information for the duration of users’ membership with their given consent. In principle, once the purpose of gathering and using provided personal information is fulfilled (ex. on request of membership withdrawal, closing of a participatory event), the relevant information will be eliminated immediately. (However, to prevent undesired membership withdrawal due to any identity theft and account-takeover identity theft, the user’s personal information will be stored for 15 days after requesting account deletion.)

1) Reasons for retaining personal information under the company's internal guidelines

The Company may retain personal information collected through events or promotions for a maximum of 1 year. The duration may differ depending on each event or promotion, and the period of collecting and utilizing data guided in each event or promotion will be employed first.

In principle, the Company instantly eliminates users’ personal information once the purpose of collecting and utilizing relevant information is fulfilled or the duration for preserving and utilizing relevant data is expired. The procedure and operation of deleting personal information are as follows:

① Deletion Procedure

Users’ personal information will be instantly erased once the purpose of collecting and utilizing relevant information is fulfilled (15 days after the grace period for membership withdrawal). However, it is held for a certain period, for the purpose of information protection as stipulated by the law (refer to “4. How long does 2NDLifeGames retain the information?”).

② Deletion Method

Personal information printed out on paper (printed material, papers, etc.) is shredded or incinerated, and information saved in the form of an electronic format is permanently deleted in such a way that it cannot be recovered.

5. How is the information protected?

The Company uses the following technology, management, and physical measures to prevent data loss, theft, breach, alteration, and destruction. However, the company is not liable if the data is leaked due to your negligence such as poor password management or mishaps outside of the company’s control.

1) Technology

- The Company encrypts the information specified when it gets stored.
- Files and data transfers containing important information (including your personal information) are protected by encryptions, file locks, or other such protection methods.
- The Company has backup systems to prevent your information from getting leaked or destroyed. The company utilizes anti-virus programs, firewalls, and other various security devices to protect your information.
- The Company is taking the necessary security measures for its systematically organized database system to process personal information.

2) Management

- The Company keeps access rights to your information to a minimum. The minimum number of personnel given access to your information are the following:
① Personnel that are directly involved with marketing, events, customer support;
② Personnel that are in charge of personal information including our Data Protection Officer;

3) Physical Security

- Documents with personal information and other forms of information storage are installed by locking devices in safe locations.

6. What information is automatically collected (e.g. cookies)?

The Company uses ‘cookies’. Cookies are small text files sent by the company’s official website that are stored in your hard drive. The following information pertains to the use of cookies, etc.

1) Purposes for using cookies

Analysis of subscribers and non-subscribers accessing our official website and duration, to understand and track user preferences and interests, provide other personalized services by tracking the number of times the website has been accessed, as well as other information.

The Company and third-party analysis service providers use tracking technologies such as cookies, beacons, tags, or scripts. These technologies are generally used by the company to collect statistics about the websites to analyze tendencies, manage the website, and to understand how our website is used. The Company may receive collected data as a whole from analysis service providers that use these technologies.

2) How to block cookies from getting saved

You have the right to block cookies from getting saved on your hard drive. This can be done by going to your web browser’s option settings to allow all cookies, ask for permission each time cookies get saved, or to block all cookies from getting saved. However, if the user refuses to have cookies saved, some services may be no longer available.

- Internet Explorer: Go to [Tools] at the top of the browser → [Internet Options] → [Personal Information] → [Advanced]
- Chrome: Go to [⋮] at the top-right of the browser → [Settings] → [Privacy and security] → [Cookie and other site data] to change your settings.
* Other web browsers adhere to their respective settings.

7. How do you contact 2NDLifeGames?

If you have any questions about personal information protection or have issues related to personal information, please send an inquiry through Customer Support on our official website. The Company will answer your inquiries as soon as possible. Also, you may report any of your concerns regarding personal data while using our services to the personnel or department in charge of personal data protection. The Company will do its best to thoroughly address and answer all complaints as quickly as possible. Please contact the following e-mail address if you need to report or receive consultation about personal information.

two2nlifegames[at]outlook.com