Privacy Policy
Last Updated: May 11, 2021
Gnarly Game Studio
Gnarly Game Studio (“we” or “us”) collects, stores, and uses personal
information of its users (“you”) as a data controller in connection with and in
order to provide and develop our products, mobile applications, services,
websites as well as other services (collectively “Services”) to ensure the
highest quality service is provided to you.
In order to prevent any improper use of your valuable personal information,
and in the interest of clarifying the purpose, methods, and scope of its
collection and use of your personal information, we have established this
privacy policy (“Privacy Policy”), and collect, store, and use your personal
information according to this Privacy Policy. This Privacy Policy applies to
any person or entity that uses our Services, EXCEPT to a resident of the
Republic of Korea. If you are using our Services in the Republic of Korea,
please refer to our Privacy Policy in Korean.
This Privacy Policy can be found on the first page of our website
(https://www.gnarlygamestudio.com) for your ease of reference. All LINE
Games Services are governed by this Privacy Policy, and by using or
accessing a Service you give consent to the processing, use, and
disclosure of your personal information. Please do not install or use
the Services if you do not agree to this Privacy Policy.
We reserve the right to modify this Privacy Policy, which may be updated
from time to time in accordance with changes in relevant laws and
regulations and/or our internal policy. Your continued use of Services will
constitute your acceptance of the changes to this Privacy Policy.
1. Personal Information We Collect
1.1 At the time of user registration and use of the Services, the information
listed below may be collected and used by us for purposes of maintaining
the continuity of Services and providing appropriate customer assistance:
A. User ID, game version information, and device information (model name,
OS version information, available memory and hard drive capacity, device
identification number, IP address, language, and country settings);
B. If the Services are connected to third party platforms such as SNS, chat
services, etc., then the user ID, nickname, contact information such as
friends list, profile pictures, for such third party platforms(third party
information is used only temporarily and is not permanently stored);
C. When you join as a member of our online community, we collect
information, including your email address, password, SNS account
information for the purpose of managing membership-related activities; and
D. Service usage records, login access records, payment records created
during the course of using the Services.
1.2 If you seek to participate in sweepstakes or advertisements, and/or
purchase paid content, all of which are supplementary services that
operate primarily based on your personal information, we will first give
notice to you and obtain your consent prior to collecting and using the
information including name, address, and mobile phone number.
1.3 When you purchase Virtual Money and Virtual Goods or when we
provide you with refunds, we may collect your information, including mobile
phone number, e-mail address and purchasing market ID.
1.4 We install and operate certain mechanisms to provide you with services
tailored to your specific interests:
A. We may use cookies that automatically collect personal information in
order to provide you with personally customized services. Cookies are
small text files of information sent by the web server used for the operation
of an application to your device to be stored within the device memory.
Once this happens and you subsequently run the same application, the
application’s web server reads the information provided by the cookie
stored within your device to maintain your preferred settings and to provide
customized services. We use cookies for the following purposes:
i. To analyze your access frequency, visit times, browser history, etc.;
ii. To analyze your preferences and areas of interest;
iii. To conduct research and diagnostics to improve our Services;
iv. To promote your convenience;
v. To prevent fraudulent activities; and
vi. To improve security
You retain the right to accept or refuse the installation of cookies.
Therefore, you may allow the installation of all cookies, request notification
for installation of each cookie, or refuse the installation altogether by
configuring the device settings or options accordingly. However, when you
refuse the installation of all cookies, you may not be able to access or use
our certain Services requiring cookies.
B. We may use third party service providers and collect personal
information as provided by the service providers, in order to analyze trends
and user behaviors to improve our Services and develop new Services.
You may withdraw your consent by deactivating such functions in
advertising settings of the service providers or the advertising settings for
mobile apps. For more information about their privacy practices and
opt-out possibilities, please visit the links below.
- Facebook、Inc. (Facebook Ads & analytics)
https://www.facebook.com/about/privacy
- Google LLC (Google Ads, analytics & AdMob)
https://policies.google.com/technologies/partner-sites
- Adjust GmbH
https://www.adjust.com/terms/privacy-policy
C. We may use advertising measuring/tracking tools to provide you with
services tailored to your specific interests. You may withdraw your consent
by deactivating such functions in advertising settings on your device.
1.5 You and your legal representatives may refuse the collection and have
the right to withdraw consents you made regarding the processing of
personal information at any time. This withdrawal of consent does not
affect the lawfulness of processing or transfers of your personal information
before its withdrawal. If you wish to withdraw your consent, you can
terminate user registration or contact us at our contact information provided
in Section 11.
2. Methods of Collecting Personal Information
We may collect your personal information using the following methods:
A. Information you provided while using our websites or Services;
B. Information received from third parties such as affiliates, business
partners, etc.; and
C. Information collected from your network communication information and
browser history.
3. Purpose for Collecting and Using Personal Information
3.1 We may use the collected personal information for the following
purposes:
A. User Management - Personal identification when providing contents,
verification of existing registration, verification of age and gender,
verification of nationality, management of delinquent users, monitoring and
detecting to deter unauthorized or fraudulent use of or abuse of Services,
performance of contracts, and processing of disputes;
B. Provision of Services - Processing customer complaints and providing
other general customer services; provision of notices; provision of paid
services and details of payments; supporting cooperative gameplay and
community services;
C. Development of New Services and Utilization for Marketing and
Advertising - Provision of Services and additional Services to users,
provision of information regarding new events, improving quality of
Services, aggregating anonymized statistical data regarding Services and
any additional Services; and
D. Provision of Auto-function for Adding and Registering of Friends -
Provision of automated functions for adding and registering friends by
collecting and using users’ mobile phone numbers and the phone numbers
of third parties stored in the users’ mobile devices.
3.2 We process your personal information only when we obtain consent
from you, EXCEPT in any of the following circumstances:
A. When processing is necessary for the performance of contract(s) to
which you are a party, or when processing is necessary to take steps at
request from you prior to entering into a contract.
B. When processing is necessary for compliance with a legal obligation to
which we are subject. (Such as following order from government agencies
to disclose information based on laws, etc.)
C. When processing is necessary in order to protect your vital interests or
of other individuals.
D. When it is deemed appropriate to investigate, prevent, and take
measures against illegal acts or suspicious acts.
E. When it is necessary for us to process legitimate interests pursued by us
or a third party to the extent that it does not infringe on your privacy rights,
interests or freedoms.
4. Sharing and Provision of Personal Information
4.1 As a principle, we do not provide your personal information to third
parties EXCEPT under the following circumstances:
A. You have provided your prior consent;
B. Third Party Service Providers – We may use third party service
providers, such as payment gateway companies, platform service
companies, analytics and ad serving companies to assist us in providing or
improving the Services. We share your personal information with these
third party service providers in order to receive their services. These
service providers may store your personal information in countries or
regions which do not have the data protection laws at the level that is
required in your country or region. In such a case, we will take measures
to protect your personal information such as entering into a contract
regarding data protection. We strictly evaluate all such third party service
providers. We take reasonable steps to ensure that they have established
appropriate and secure information administration and organizational
control systems. We impose binding contractual obligations on such
service providers to comply with applicable laws and regulations regarding
the processing of personal information. We also require that they access
your personal information only to the extent necessary to perform tasks in
accordance with our instructions, and for no other purposes.
C. Mergers and Corporate Transactions – In the event that we undergo
business transitions such as a merger, acquisition, joint venture, corporate
divestiture or dissolution, a sale of assets, or similar transactions, we may
share, disclose, or transfer your information, including personal information,
to the other organizations that are parties to such transactions;
D. Sweepstakes and Promotions – We may share your personal
information for any sweepstakes or promotions you enter in connection with
the Services in order to administer, market, sponsor or fulfill such
sweepstakes or promotions as necessary, or as required by applicable
laws, rules or regulations; and
E. Legal Purposes – We may provide your personal information to third
parties in cases where we have a good faith belief that doing so is required
by law or in order to cooperate with regulators or law enforcement
authorities. We may also provide your personal information to third parties
in order to protect the rights or property of a third party or us, including
enforcement of our Terms of Service.
4.2 Please note that you may choose to disclose your personal information
in the course of contributing user-generated content to the Services. Any
data you disclose in any of these forums, blogs, chats or the like will
become public information, and there is no expectation of privacy or
confidentiality with respect to that information.
4.3 We may store and/or transfer your personal information to our affiliates
and partners in and outside Turkey, EU/EEA member states and the United
States in accordance with mandatory legislation and this Privacy Policy. In
such events, we will obtain your explicit consent, as we strive to protect
your personal information in accordance with personal information
protection laws of your country or region.
5. Collection and Use of Children’s Personal Information
5.1 We do not knowingly collect any personal information from anyone
under the age of 13 (under the age of 16 in Europe), unless consent is
given by a parent or legal guardian. If you are under 13 years of age (16 in
Europe), please do not send us any information about yourself, and you
should not use or attempt to use our Services. Some of our Services have
age restrictions which may vary depending on countries, regions, OS,
platforms, etc. If you are under the applicable age restrictions, please do
not send us any information about yourself and you should not use or
attempt to use our Services. Please refer to our Terms of Service for further
information.
5.2 In the event we learn that we have inadvertently gathered personal
information from children under the age of 13 (16 in Europe), we will take
reasonable measures to promptly delete such information from its records
in a secure manner. If you believe that we may have any information from
or about children under the age of 13 (16 in Europe), please contact us at
our contact information provided in Section 11.
5.3 Please note that all persons under the age of majority are required in
their respective jurisdictions to have a parent or guardian read and accept
this Privacy Policy and the Terms of Service on their behalf. Parents are
encouraged to supervise their children’s use of our Services and to become
familiar with the types of content available through our Services. Parents
should oversee their children’s use of e-mail, forum and other online
communications.
6. Security of User Information
We follow generally accepted industry standards and maintain reasonable
safeguards to attempt to ensure the security, integrity, and privacy of the
information in our possession. As further security measures, we implement
the following technical and managerial safeguards to ensure that any
personal information of users we handle is secure from loss, leaks, or
damage:
A. Improving Network Security - We implement various technical
measures to prevent the leakage of your personal information by
unauthorized access to its network via hacking, computer viruses, etc., and
continuously monitor network access.
In addition, to ensure the security of communications between its server
and database, we use strong encrypted communication methods.
B. Conduct Security Training and Designation of Privacy Officer - We
conduct regular security training for our employees on the protection of
your personal information. Furthermore, we have designated a privacy
officer to develop expertise in the handling of your personal information and
to minimize the risk of information leakage.
C. Restrict Access and Storage - The location in which the handling and
storage of personal information are performed has been designated as a
secure area and access thereto has been restricted to personnel with the
requisite authority. Documentation, storage mediums, and electronic
records containing personal information are stored in a location equipped
with a locking device or on a computer with restricted access.
7. Management of Personal Information and Your Choice
7.1 We make good faith efforts to give you a right to access your personal
information to have errors in your personal information rectified, to object to
the processing of your personal information on legitimate grounds, data
portability, etc. You and your legal representatives may review and change
your personal information through the user information review/change
function provided by our Services or through a written request to a
customer service representative. However, in cases where your personal
information is connected to a third party platform such as SNS, chatting
service, etc., any requests for review and changes to personal information
must be made in accordance with the procedures provided by such a third
party platform operator.
7.2 To exercise any of your other rights under applicable law, you may
contact us using our contact information in Section 11. Upon verification of
your identity, we respond to your request within a reasonable period of
time, and in accordance with relevant laws. If, however, permitted under
applicable laws, we may not be able to respond to your request when any
of the following applies:
A. Disclosure is likely to harm the life, body, property, or other rights or
interests of yours or another individual;
B. Disclosure is likely to seriously impede the proper execution our
business;
C. Disclosure violates other laws; or
D. When you failed to verify your identity upon your disclosure request.
7.3 In the event that you request us to correct certain inaccuracies
regarding your personal information, we will take necessary measures to
rectify the situation, including correcting the inaccuracies without delay or
providing an explanation to you as to why the inaccuracies remain
unchanged. Any personal information that is subject of the foregoing
request will not be used or provided to a third party until after we have
taken the aforementioned necessary measures. Notwithstanding the
foregoing, we may still use, or provide the personal information of a third
party, when it receives a request for personal information pursuant to
applicable laws or regulations.
7.4 You have the right to object to our processing of your personal
information. You may object to the processing of your information in the
following circumstances:
A. Personal information is processed for directing marketing purpose
(includes profiling);
B. Processing is necessary for the purpose of the legitimate interests
pursued by the controller;
C. Processing is necessary for the performance of a task carried out in the
public interest or in the exercise of official authority vested in the controller;
and
D. Personal information is processed for scientific or historical research
purpose
7.5 Any collected personal information will be retained and used as long as
your user status with our Services is maintained; for the length of time
needed to fulfill any of the applicable purposes of use described in this
Privacy Policy; or to comply with laws and regulations. We may retain your
personal information following the closure or termination of your user
account if retention is reasonably necessary to comply with applicable laws,
regulations or legal obligations; to provide and complete customer support
service; to resolve disputes between or with other users, for the duration of
the applicable limitation period; or to detect and deter unauthorized or
fraudulent use of, or abuse of Services.
A. Right to Erasure - You have the right to request us to destroy personal
information without undue delay. You may exercise this right by contacting
us using our contact information in Section 11.
B. Destruction Process - We will destroy personal information when 1)
requested by you and/or 2) that is past its retention period using the
methods that prevent recovery of such information.
C. Destruction Methods – 1) Personal information saved in a digital
format is permanently deleted by using a technology that prevents recovery
of record and 2) Personal information printed on paper is destroyed by
shredding or incinerating the document.
8. California Privacy Rights
This Section shall apply to California residents only. Under the California
Consumer Privacy Act (the “CCPA”), California consumers have the right to
request that we disclose what personal information we collect from you, to
delete the information, to opt-out of the sale of your personal information,
and the right not to be discriminated against for exercising one of your
California privacy rights. We do not sell your personal information and do
not discriminate against you in response to privacy rights requests.
A. Right to Opt-Out – We use and share your personal information only in
accordance with this privacy policy. We do not believe this use and sharing
is a sale under the CCPA. We have not sold your personal information in
the last 12 months and we currently do not have any plans to sell your
personal information in the future.
B. Shine the Light Law – We do not share your personal information with
third parties for the purpose of direct marketing.
C. Do Not Track – California law requires us to inform you how we respond
to web browser Do Not Track signals. Because there is no industry or legal
standard for recognizing or honoring Do Not Track signals, we do not
respond to Do Not Track signals at this time.
D. Exercising your rights – If you want to exercise your California privacy
rights or if you have any questions regarding our practices, please email us
at info@gnarlygamestudio.com.
9. Legal Matters
9.1 If any court or other competent authority finds any of the terms of this
Privacy Policy to be invalid or unenforceable, the remaining terms of this
Privacy Policy will not be affected and will be given full force and effect.
9.2 This Privacy Policy is governed by, and interpreted in accordance with,
the laws of Turkey. Any disputes arising in connection with this Privacy
Policy will be subject to the exclusive jurisdiction of the courts of the Turkey.
9.3 We are constantly innovating and looking for new ways to improve our
Services and websites. We may therefore modify this Privacy Policy from
time to time to reflect such improvements or any other changes to our
business. We strive to inform you about any significant changes to this
Privacy Policy that may be viewed as possibly disadvantageous to you in
any material way. If you object to any of these changes, please stop using
the Services immediately and close any account you may have with us.
10. Changes to Privacy Policy
The Privacy Policy may be updated from time to time to reflect any
changes to relevant laws and regulations or to our internal policy. We will
provide notice regarding any changes to the Privacy Policy before such
changes are scheduled to take effect by 1) disclosing the changes on our
website; and/or 2) any other conspicuous means within the Services that
allow you to learn about the changes.
