PRIVACY POLICY

1. 1.1. Welcome to "The Game" or "Game", operated by RGS Online Pte. Ltd. and its affiliates ("we," "us," or "our"). We take our responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and are committed to respecting and protecting the privacy of our users.
   
2. 1.2. This Privacy Policy explains:
   1. (a) What personal data related to your Game Account and gameplay we collect from you;
   2. (b) How we collect, use, disclose, and process your Game-related personal data;
   3. (c) Who we may share your Game-related data with;
   4. (d) Your rights regarding your Game Account information and other personal data; and
   5. (e) How we safeguard your Game Account and related data.
3. 1.3. By accessing or using our Services or the Game, including, but not limited to registering for a Game account, or interacting with our in-game features and services, you acknowledge and consent to the collection, use, disclosure, and processing of your personal data as described in this Privacy Policy. If you do not agree to this Policy, please refrain from using the Game, your Game Account or related in-game services.
   
   
4. 1.4. This Privacy Policy applies alongside any other terms, notices, or agreements that may govern our relationship with you concerning data protection. We may update this Privacy Policy from time to time, and continued use of the Game or our services after such updates constitutes your acceptance of the revised policy.
   
   
5. 1.5. This Privacy Policy applies to all users of the Game and its Services, regardless of the platform used (including mobile devices, PCs, or third-party platforms such as app stores or social logins). If specific policies apply to certain regions (e.g., GDPR for the EU, CCPA for California), we will provide additional notices where required.
   
   

When you access or use our Services or the Game, we may collect and process the following types of personal data:

1. 2.1. Information You Provide to Us

   You may provide personal data directly to us when using the Game, such as:

   • • Game Account Information – Game Account username, account ID, profile picture, character name, and other details related to your in-game account.
   • • Contact Information – name, email address, phone number, and other details you provide when creating Service support tickets or subscribing to Service-related communications.
   • • Transaction Data – payment information, purchase history, and details related to in-game purchases (processed by third-party payment providers).
   • • User-Generated Content – messages, in-game chat logs, friend interactions, guild messages, forum posts, gameplay recordings, or other content you create and share.
   • • Survey or Feedback Information – responses to Game-related surveys, promotions, or customer feedback forms.
   • • Third Party data – Facebook ID and Google ID tied to Service use.
2. 2.2. Information Collected Automatically

   When you use our Services or the Game, we may collect certain information automatically, including:

   • • Device and Technical Information – IP address, device type (e.g. PC, iOS, Android), operating system, browser type, and mobile network details.
   • • Game Usage Data – session duration, gameplay statistics, in-game interactions, and feature usage patterns.
   • • Cookies and Tracking Technologies – data collected via cookies and similar tools to enhance your gaming experience and enable personalized content.
   • • Location Data – approximate or precise location data (such as GPS coordinates), subject to your device settings and permissions, as well as your in-game settings.
   • • Personal Data – automatically collected identifiers or account-related information that may be linked to your identity (for example, unique device IDs or account identifiers provided through integrated login methods). Note: In cases where you have authorized access via social or third-party accounts, additional profile details (such as your username or profile picture) may be captured automatically.
   • • Game-Specific Non-Personal Data – data pertaining to your game behavior and performance that does not directly identify you, such as achievement records, level progress, in-game currency balances, and aggregated statistics.
3. 2.3. Information from Third-Party Sources

   If you connect to our Services or the Game to third-party services (e.g., social media, game distribution platforms), we may receive:

   • • Linked Account Data – details from your linked accounts: including, but not limited to display name, friends list, or profile picture.
   • • Marketing and Analytics Data – information from external partners for analytics, advertising, or fraud prevention.
4. 2.4. Compliance and Security

   To ensure compliance with legal and security requirements, we may collect:

   • • Fraud Prevention Data – information used to detect and prevent cheating, fraud, or other malicious activities (including but not limited to third-party software use and account hacking).
   • • Legal or Regulatory Data – identity verification documents (if required by law, for age verification purposes or account ownership verification).
5. 2.5. Opting Out or Managing Data Collection

   You may have the ability to limit certain data collection through your device settings, Game Account preferences, or by contacting us. However, restricting data collection may affect your experience with the Game and its services.

This section explains how we use the personal data collected through our Services and the legal grounds for processing it.

We process personal data based on the following legal justifications:

• • Consent – When you have given us explicit permission to process your data.
• • Contract Performance – When processing is necessary to fulfil a contract with you.
• • Legal Obligation – When required to comply with applicable laws.
• • Legitimate Interests – When processing is necessary for our business interests, provided it does not override your rights.
• • Legal Claims – When processing is required for legal actions, disputes, or compliance purposes.

If you have given consent for a specific use, you may withdraw it at any time, but this will not affect any processing carried out before your withdrawal. If we process your data based on legitimate interests, you have the right to object, though this may impact your ability to use certain features of the Game. Additionally, we may share your data with Game-related service providers, partners, legal advisors, anti-cheat providers and affiliated companies that support our operations.

1. 3.1. To Provide and Manage Our Services

   We process personal data to:

   • • Operate our Services, the Game, Game Account and in-game features.
   • • Manage your User ID, in-game preferences, and interactions (including but not limited to friend lists, guilds, leaderboards)
   • • Fulfil our contractual obligations and notify you of changes to our Game Services.
   • • Legal Basis: Contract performance, consent, legitimate interests (ensuring smooth gameplay and service delivery).
2. 3.2. Sponsorship and Promotions

   If we sponsor you or your e-sports team, we may process your data to:

   • • Fulfil event participation or sponsorship agreements.
   • • Notify you of changes to events or sponsorship terms.
   • • Publicly promote your sponsorship or Game-related achievements.
   • • Legal Basis: Contract performance, consent.
3. 3.3. Communications and Marketing

   We may process personal data to:

   • • Send service-related or Game-related notifications and Game updates.
   • • Provide personalized Service-related marketing via email, push notifications, in-app notifications, SMS, or social media.
   • • Offer promotional content (including but not limited to limited-time events or in-game store discounts) based on your preferences.
   • • Legal Basis: Legitimate interests (informing users about Service features and updates), consent (where required by law).

   You may opt out of marketing communications at any time.

4. 3.4. Service Improvement and Analytics

   To improve our Services, the Game, Game-related services and Your experience, we analyze user data to:

   • • Understand player usage patterns, session duration, feature-specific engagement metrics, and user preferences.
   • • Enhance gameplay experiences and optimize performance.
   • • Develop new features and updates.
   • • Legal Basis: Legitimate interests (ensuring Game-related quality and innovation).
5. 3.5. Security, Compliance, and Fraud Prevention

   We process data to:

   • • Monitor compliance with our Terms of Service and Community Guidelines.
   • • Detect and prevent malicious Service-related, including but not limited to fraud, cheating, and security threats.
   • • Respond to Your reports of Service-related misconduct, harassment or rule violations.
   • • Legal Basis: Legal obligations, legal claims, legitimate interests (maintaining platform integrity).
6. 3.6. Business Operations and Transactions

   In the event of business changes, we may process personal data for:

   • • Factors in our business process, including but not limited to Service-related publisher transitions, platform migrations, Service-related server transfers.
   • • Due diligence related to acquisitions or business transfers.
   • • Legal Basis: Legitimate interests (ensuring smoothened service continuity and business transitions).
7. 3.7. Legal and Regulatory Compliance

   We may disclose personal data to authorities when required to:

   • • Comply with applicable Service-related laws and regulations.
   • • Respond to government or law enforcement requests.
   • • Protect Our rights, You, or the in-Game community.
   • • Legal Basis: Legal obligations, legal claims, legitimate interests (cooperating with authorities and ensuring responsible gaming).

The advertisements and in-game recommendations (including online, while you are logged into your Game account, and while you are using our mobile app) which we show you are chosen by analysing the Personal Information you provide to us as described in section 2, including information about your past Service-related purchases from us, the way in which you use our products and/or services (including but not limited to the characters, game modes, or game-related challenges), and previous in-game advertisements which you have clicked on. To choose advertisements which are tailored and most likely to be of interest to you, we compile and analyse information received from all our customers to gain a better understanding of your preferences from customers like you. We use similar predictive techniques to combat payment fraud, unauthorized access and account misuse within the Game.

When you create an Service account, link third-party gaming platforms, or initiate a transaction on our site, we may process your Personal Information (including but not limited to your name, mobile number, identification number, passport number, nationality, address, date of birth and related documents including your identification card, passport, proof of residence documents such as utility, phone or bank statements and/or government agency letter) for the purposes of Game account authentication and security verification, preventing fraudulent transactions, unauthorized Game Account access, and duplicate account creation. If the Personal Information submitted to us is insufficient, inaccurate and/or does not pass our identity verification checks in our view, we may disable your account and/or decline to process your in-Game transaction(s).

When you submit Service-related payment request via our system, we pass your payment information (including information about your past transactions, the current transaction, your user ID and IP address) to a third-party service provider, which conducts anti-fraud checks on our behalf. This process may result in your payment being declined or flagged for review. You may want to check your payment information or try again using a different method of payment. Otherwise, you may request that we provide information about our decision-making methodology and ask us to verify that the automated decision has been providing the information would result in a disclosure of a trade secret or would interfere with the prevention or detection of fraud or other crime but generally in these circumstances, we will ask our third party service provider to verify that its algorithm and source data are functioning as anticipated without error or bias.

1. 7.1. Security of Your Personal Information
   • • We implement industry-standard physical, electronic, and procedural safeguards to protect your Personal Information from unauthorized access, use, modification, destruction, disclosure, loss, or theft of your Game Account.
   • • We have agreements with third-party service providers requiring them to safeguard any Personal Information we share and to use it solely for the services they provide on our behalf.
   • • While we take reasonable steps to secure your data, no system is entirely immune from external threats. By using our Services, you acknowledge that we cannot guarantee absolute security against unauthorized access or breaches.
2. 7.2. Security of Data Transmission Over the Internet
   • • We employ commercially reasonable measures to protect your Personal Information in compliance with applicable data protection laws. However, no method of transmission over the Internet is completely secure, and we cannot guarantee that data will not be accessed, altered, or compromised.
   • • Your Service Account security also depends on you. If we provide you with, or you choose a password to access parts of our Services, you are responsible for keeping it confidential. Please do not share your Service Account password with anyone and ensure you log out after each session. If you suspect unauthorized access to your Game Account, notify us immediately.
3. 7.3. Retention of Your Personal Information
   • • We retain your Personal Information associated with your Service Account for as long as necessary to fulfil the purposes for which it was collected, as well as to comply with legal, regulatory, or operational requirements.
   • • When Personal Information is no longer required, we will securely delete, anonymize, or otherwise dispose of it in accordance with applicable laws and industry best practices. In some cases, we may retain anonymized data for research, analytics, or statistical purposes.

Most of our processing is permitted by "legal grounds" other than consent (see section 2 above). In relation to Direct Marketing, where we are required to do so, we will obtain your consent before using your Personal Information associated with your Service Account for this purpose. If you prefer not to receive our Direct Marketing communications and/or not have your Personal Information shared among the members of our group for the purpose of marketing, you can have your name deleted from our Direct Marketing and/or shared information lists.

Direct Marketing means our communication with you such as mail, telemarketing or email, using your contact information associated with your Game Account, to inform you about Service-related products and services that we think may be of interest and value to you. This does not include communications regarding products or services that you currently have, including improved ways to use the products, or additional features of the products as well as transactional information.

We will use reasonable endeavours to ensure that your Personal Information is accurate. To assist us with this, you should notify us of any changes to the Personal Information that you have provided to us by contacting us as set out in the "Contacting Us" section below.

If you have any questions in relation to our use of your Personal Information associated with your Service Account, you should first contact us as per the "Contacting Us" section below. Under certain conditions, you may have the right to require us to:

1. (a) provide you with further details on the use we make of your information;
2. (b) provide you with a copy of information that you have provided to us in relation to your Service Account;
3. (c) update any inaccuracies in the Personal Information we hold in relation to your Service account;
4. (d) delete any Personal Information that we no longer have a lawful ground to use;
5. (e) where processing is based on consent, to withdraw your consent so that we stop that particular processing;
6. (f) object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;
7. (g) restrict how we use your Service Account related information whilst a complaint is being investigated; and
8. (h) Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights, we will check your entitlement and respond in most cases within a month.

We use cookies on the websites. To find out more about how we use cookies, please see our Cookie Policy.

We may change the content of our websites and how we use cookies and consequently our Privacy Policy and our Cookie Policy may change from time to time in the future. If we change this Privacy Policy or our Cookies Policy, we will update the date it was last changed below. If these changes are material, we will indicate this clearly on our website.

If you are using our Services in Vietnam, the following additional terms apply. In the event of any conflict between these additional terms and the provisions set forth in the main body of this Privacy Policy, these additional terms shall take precedence.

1. 13.1. Age, Parental and Guardian Consent

   By accessing and/or using our Services, you acknowledge that you are at least 16 years of age, or you are not under legal guardianship. If you are below 16 years of age or are under legal guardianship, you must:

   • • Obtain explicit consent from your parent(s) or legal guardian(s); and
   • • Ensure that your parent(s) or legal guardian(s):
   • i. Assume full responsibility for all your actions in connection with your access to, and use of our Services;
   • ii. Ensure your compliance with this Privacy Policy; and
   • iii. Guarantee that any of your participation in these Services, will not, in any event, result in the violation of any applicable laws and regulations relating to child protection.

If you do not have said requisite explicit consent from your parent(s) or legal guardian(s) and your parent(s) nor legal guardian(s) are willing to open the account under their name, you must immediately discontinue the use of our Services.

If you are using our Services in the Philippines, the following additional terms shall apply pursuant to the Data Privacy Act of 2012 (Republic Act No. 10173) and all relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.

1. 14.1. Your Rights

   Subject to the applicable data privacy laws and regulations, you are entitled to the right to be informed about the collection and processing of your personal information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages, and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

2. 14.2. Contact Us

   If you have any inquiries regarding this Privacy Policy, or would like to complain about a violation of the Data Privacy Act of 2012, or have concerns about the handling of your personal data, you may contact the data protection officer by emailing us at dpo@rgsonline.com. You have the right to access your personal data and seek correction of it. Please contact the DPO on the details provided in this Privacy Policy if you wish to access your personal data and/or seek correction of your personal data. If you are not satisfied with the response or do not receive a response within a reasonable timeframe, you have the right to file a complaint with the NPC, on their website at https://www.privacy.gov.ph.

If you do not have said requisite explicit consent from your parent(s) or legal guardian(s) and your parent(s) nor legal guardian(s) are willing to open the account under their name, you must immediately discontinue the use of our Services.

If you are using the Services in Indonesia, the following terms shall apply. In the event of any conflict between these additional terms and the provisions set forth in the main body of this Privacy Policy, these additional terms shall take precedence.

1. 15.1. Age, Parental and Guardian Consent

   By accessing and/or using our Services, you acknowledge that you are at least 21 years of age, not under legal guardianship, or you are married. If you are below 21 years of age or are under legal guardianship, you must:

   • i. Assume full responsibility for all your actions in connection with your access to, and use of our Services;
   • ii. Ensure your compliance with this Privacy Policy; and
   • iii. Guarantee that any of your participation in these Services, will not, in any event, result in the violation of any applicable laws and regulations relating to child protection.
2. 15.2. Your Rights

   You have the right to withdraw your consent to our disclosure of your personal data to third parties. Upon your request, we will take steps on our end to cease to display, publish, transmit, disseminate, and/or open the access to your personal data to third parties.

   Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may limit our ability to fulfil your requests, and you may not be able to use some, or even all features and functionality of the Services.

   You may request us to:

   • • Obtain a record of the personal data collected about you; and/or
   • • Request the erasure and disposal of your personal data stored on our servers.

   Please be aware that requesting us to erase and dispose of your personal data we have collected, you may not be able to use some or even all features and functionality of our Services. To exercise any of your rights, you may look below in the “Contact Us” section.

3. 15.3. Contact Us

   If you have any inquiries regarding this Privacy Policy, or would like to complain about a violation of your aforementioned rights, or have concerns about the handling of your personal data, you may contact the data protection officer by emailing us at dpo@rgsonline.com. You have the right to access your personal data and seek correction of it. Please contact the DPO on the details provided in this Privacy Policy if you wish to access your personal data and/or seek correction of your personal data.