Privacy Policy

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to Code: K (“Game”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

For the purpose of data protection laws, the data controller of your personal information in relation to the Game is Proxima Beta Pte. Ltd..

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

What information do we need to be able to provide the Game?	If you register an account to use the Game then we will need some information from you to set this up. This includes your email address.Depending on your use of the Game and the jurisdiction where you are based, you may also need to provide some additional information to help us set up your account. To maintain the smooth operation of the Game (which includes activities such from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information (such as IP address, connection speed, device specifications, as well as app- and OS-generated identifiers). If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns.	More Information.
How will we use your information?	We use your information to set up your account, enable you to use the Game, localise the Game experience, enable interaction between users of the Game, save your progress, ensure the safe and secure operation of the Game, address bugs, optimise and improve the Game, protect users, monitor our marketing initiatives, enable transactions, resolve user queries, and to comply with our legal obligations and enforce our legal rights. We use your information to facilitate your communications with other players through voice chats and text chats, and ensure a safe gaming environment.	More Information.
Who do we share your information with?	We use third parties and work with our affiliates to help us deliver the best possible experience. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game (i.e., to fulfil the purpose(s) described above). In some cases, we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.	More Information.
Where do we process your information?	Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. We have servers for the Game in Singapore and United States of America (USA). The servers applicable to your use of the Game will depend upon your location. We also have support, engineering and other teams who may support the Game, including from Singapore and the USA	More Information.
How long do we keep your information?	Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Game, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.	More Information.
How can I exercise my rights over my information?	Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.	More Information.
How will we notify you of changes?	Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.

Welcome to PGame!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with Code: K (the “Game” ), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Game. If you use any other products or services please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Game. By using the Game, you are acknowledging how we process your personal information as described in this Privacy Policy.

For the purpose of data protection laws, the data controller of your personal information in relation to the Game is Proxima Beta Pte. Ltd. (“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at codek@levelinfinite.com We have representatives for data protection purposes listed here.

1. Children

Children must not use the Game 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; 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 as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

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.

Region in which the user is located	Minimum age of the user
Philippines	18

2. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

Personal Information	Use	Legal Basis (where applicable)
Information you provide to us (either directly or through a third party)
Name, nickname, alias, email address	We use this information to create your account for the Game in accordance with your request.	Necessary to perform our contract with you to provide the Game.
Gender of game character	We use this information in order to customise the Game.	We use this information with your consent.
Compliance Information: minor confirmation,	We use this information to verify your eligibility to use the Service and to comply with applicable laws.	It is in our legitimate interest to ensure compliance with applicable age-gating rules.
Region Location (manually selected by you)	We use this information to: set up your use of the Game on a regional server; provide you with your geographic ranking; and improve gameplay.	Necessary to perform our contract with you to provide the Game.
Telephone number and/or email address and/or associated social media account (if you elect to provide this information to receive game updates).	We use this information to send you verification codes or information on our game updates via SMS or email.	To the extent applicable and permissible in the relevant jurisdiction(s), it is in our legitimate interest to provide you with Game updates. Otherwise, we collect this information with your consent.
Email address	We use this information to provide a manual customer service ).	Necessary to perform our contract with you to provide and support the Game Services.
Email address (if you elect to provide this information to bind your account with your email address)	We only receive this information if you choose to enable login by email address (once verified by way of a verification code sent to you).	Necessary to perform our contract with you to provide the Game using your email address.
Telephone number (if you elect to provide this information to bind your account with your telephone number). This includes SMS Sending Records	We only receive this information if you choose to enable login by mobile phone number (once verified by way of a verification code sent to you).	Necessary to perform our contract with you to provide the Game using your phone number.
Two-factor authentication information: telephone number, email address (optional), device ID, device model. This includes SMS Sending Records	If you choose to bind your phone number and enable two-factor authentication, we use this information for verification when you log in from a new device.	Necessary to perform our contract with you to enable two-factor authentication.
Data Subject Request Information: country/region, name, user email address, screenshot of user ID and user nickname, user ID, account registration date, login method, account UC balance, account BP balance, request details, any other information necessary to verify your identity, and if the request is made by a requestor on your behalf, name of requestor, email address of requestor, requestor's relationship with you, proof of your identity and requestor's authority	If a data subject request is submitted, we use this information to confirm your and, if applicable, the requestor’s identity, your rights and to process the request.	Necessary to comply with a legal obligation.
Information generated as part of the Game
User ID	We generate this and use this to: store your Game data (including level and progress) with your profile; to support your use of the Game and Game activities; and to allow you to delete your account.	Necessary to perform our contract with you to provide and support the Game.
Battle Information: user data (such as channel, user ID, nickname) and game data (such as gameplay mode information, number of kills, movement speed, jump height)	We generate this and use this to enable you to play the Game.	Necessary to perform our contract with you to provide and support the Game.
IP Address	We use this information to: allow you to connect to the Game server; and suggest your country/region when you seek to change your location setting.	Necessary to perform our contract with you to provide the Game.
Device ID, Device Information application version, battery information, WiFi strength, available space, network type, OS version, platform, carrier, country code, series ID, , device name, device language, screen DPI, system file information, screen size, device resolution, screen direction, brand, manufacturer, device model, device statistics (of cameras, sensors, systems), XID (if you are a guest user, generated from your existing device information, model, manufacturer), RAM, ROM and CPU information, GPU version number, baseband information, registration time and login time	We use this information: to confirm the current network type; to provide users with network type display; to display content in the relevant language; to facilitate automatic download of important resources via WIFI; to facilitate account data migration of guest accounts from the Game to its mini version and for security control and analysis; to improve our services, including the functionality of the Game; to provide a Q&A function and customer service; for security and verification purposes; identify and address bugs and assess game function for optimisation; and to combat users registering for multiple accounts.	It is in our legitimate interest to ensure the security of our services, show you content that may be more relevant to you and your interests, manage registrations and improve our services.
Routing Information (if you have poor network connection): IP address, network speed	We use this information to analyse the cause of poor network connection.	Necessary to perform our contract with you to allow you to play the Game.
Chat Data (audio and text, whether inside a battle (e.g. during actual gameplay) or outside a battle (e.g. in the game lobby)) and chat log data	If you enable chat services (audio and/or text) then we will process such data in order to deliver your messages to other users.	Necessary to perform our contract with you to provide the chat services in-Game.
MSDK Information (”minor’ label, “not minor” label, openid, email address, friends list, friends’ interactions)	We use this information to: Verify your age if you are a user in certain regions Send emails for parental or guardian confirmation/ verification. We use this information to provide the service to you, in particular, construction of friend list in-game. We use this information so that you can connect with your friends and share game activities with your friends.	Necessary to perform our contract with you to provide the Game and connect you with your friends.
MSDK Automatic Login MSDK Logout Query User Information Log In with Email (OpenID, email address, telephone number, Country code) (The email address, telephone number, country code will be collected only when user using email is used to do automatic login.)	We use this information to: Verify your identity Enable logging in Generate your Game Account	Necessary to perform our contract with you to provide the Game.
MSDK Announcement Services (open id, Device language, Screen resolution, Device brand, Device manufacturer, Device model, RAM, ROM, CPU Info, application version, network type, IP address)	We use this information for: System monitoring and shielding against malicious attacks Issuing announcements based on specified device types, languages, hardware information, and user lists Conducting fault recording and analysis Network optimization	Necessary to perform our contract with you to provide the Game.
MSDK Client Server Status: Identity Information (OpenID), Device information (Device model, CPU architecture, Running process information, System Properties, System Setting), Network Type, Operator name, IP address (The abovementioned relies on the collection of: Device model, CPU architecture, Running process information, System Properties, System Setting, Network Type, Operator name, IP address)	We use this information for: System monitoring to ensure service stability Troubleshooting issues when provided with feedback as to Game service Report client server status to the server	Necessary to perform our contract with you to provide the Game.
MSDK Cloud Configuration Information (device information, Device language, Screen resolution, Device brand, Device manufacturer, Device model, RAM, ROM, CPU Info), Application version, Network Type, IP address, Application Version, Screen Resolution, Device Brand, Device Model, CPU Info)	We use this information for: System monitoring and shielding against malicious attacks Game environment configuration and verification Conducting fault recording and analysis Network optimization	Necessary to perform our contract with you to provide the Game.
TBDS SDK Information (player id, open id, device information, user gameplay behavioural records, item acquisition and consumption records)	We use this information to enable you to save your Game data, and perform statistical analysis based on Game data.	Necessary to perform our contract with you to provide and support the Game.
TGDP SDK Information (player id, open id, device information, user gameplay behavioural records, item acquisition and consumption records)	We use this information to perform statistical analysis based on Game data.	Necessary to perform our contract with you to provide and support the Game.
Gvoice SDK Information (friends’ list, friends’ interaction records)	We use this information to ensure a safe gaming environment.	Necessary to perform our contract with you to provide the Game.
GVoice Chat Data (real-time voice)	We facilitate your communications with other users, which may include translation and realtime speech-to-text functions.	Necessary to perform our contract with you to provide the Game and enable communication between users.
GVoice chat data (voice message)	We facilitate your communications with other users, which may include translation and realtime speech-to-text functions.	Necessary to perform our contract with you to provide the Game and enable communication between users.
GVoice chat data (for in-game safety): voice files	Such voice files are processed and only stored on your device, and is not processed by our servers except on receipt of a report or complaint. In case of a report or complaint, we process such voice chat data on our servers to identify and to improve the tools we use to identify spam, harmful communication, exploits, bullying, harassment, threats of violence or conduct which is hateful, ractially or ethnically offensive, defamatory, humilitating, threatening, profane or similarly objectionable.	It is in our legitimate interest to ensure the security and integrity of the Game and the safety of our users.
GVoice Text chat data	We facilitate the posting of your communications with other users.	Necessary to perform our contract with you to provide the Game and enable communication between users.
GVoice Device information and other technical information to enable voice chats and text chats (such as Open ID, device information (device name, device model, device brand, system time), client export IP, IP address, SDK version, network type, region ID	We process such information to facilitate your communications with other players through voice and text chats and ensure the safe and secure operation of the Game.	Necessary to perform our contract with you to provide the Game and enable communication between users. It is also in our legitimate interests to ensure a safe gaming environment.
IMUR Survey Information (game account information, email, country or region of residency, gaming habits and preferences (including recently played games, gameplay frequency, favourite game categories and experience, language preference, evaluation and comments towards the [Service]), and other survey responses content that you may choose to provide (see https://mur-survey-out-1255655535.cos-website.ap-singapore.myqcloud.com/privacy-policy/2020-02-13/English.html)	With your consent, we use the survey information to allow you to participate in surveys about the Game to improve the Game.	We collect this information with your consent.
Mobile Game Anti-Cheating SDK Information (behavioural records of game players)	We use this information to ensure a fair gaming environment, and for detection of any cheating behavior within the Game.	We process this information as it is necessary for us to perform our contract with you to provide the Game.
Mobile Game Anti-Cheating SDK Device Information & Identifiers: brand, model, api_level, system version, operating system version, source_dir, apk_path, lib_dir, files_dir, hardware, device cpu name, device language, vpn status, adb_enabled, usb_connected, usb_plugged, installed packages, device modules, iDevHwModel, iDevRes, iDevModel, iDevSysName, iDevSysVer, AppVer, iAppMachOUUID, iAppName, iAppMainModule, iAppCryptInfo, iAppFileCryptInfo, iScreenCaptured, ios vpn, ios language, iDevIDFV, ios modules	We only process this data for the purposes of providing the Game to you, including: Identifying suspicious device environments; Confirming SDK compatibility; Detecting of cheating behavior; Locating network problems and determining whether log-in restrictions have been by-passed; Determining whether end users’ device is in debugging mode; Determining whether end users’ device has installed modifiers, gas pedals, virtual machines, special hangers, live software, VPN software; Detecting cracked applications with tampered game version numbers; Detecting applications that have been tampered with/ cracked; Detecting cheating behavior; Detecting Game Trainers/Modifiers, Speedhack tools, Customized Cheats Upon your request, we are able to store the data collected on Tencent Cloud (Tencent Big Data Suite, TencentDB for MySQL, Elasticsearch Service, TencentDB for Redis), Google Cloud, and/or Microsoft Azure.	We process this information as it is necessary for us to perform our contract with you to provide the Game.
Mobile Game Anti-Cheating SDK Cheat Tool Detection Information: Screenshots of the product/service that incorporates the Game from end users’ perspective (does not contain sensitive information)	We use this information to review and determine whether end users have cheated in the product/service that incorporates the Game and provide end users with a safer in-game environment.	It is in our legitimate interest to ensure the security of our services and to maintain a fair environment within product/service that incorporates the Game.
Data analytics/profiling information (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 Ad ID and IDFA Firebase Instance ID and Open ID Device motion parameters, sensor data (For more information as to the information that will be processed from use of Firebase, please see https://firebase.google.com/support/privacy#data_protection)	We use this information for app performance analytics. We use the Firebase Instance ID to increase in-Game purchase rates of new users through Google platforms.	If you live in the European Economic Area: We collect this information with your consent. If you do not live in the European Economic Area: It is in our legitimate interest to use this information to provide a better gaming experience.

3. How We Store and Share Your Personal Information

Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Game in Singapore and United States of America (USA). The servers applicable to your use of the Game will depend upon your location. We also have support, engineering and other teams who may support the Game, including in Singapore and USA.

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 Game, including providers of services that process information identified in this policy for the purpose of providing the Game. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game (i.e., for the purpose(s) described above).
Companies within our corporate group who process your personal information solely for the purpose of providing the Game to you. All such group companies may only use your personal information in accordance with this Privacy Policy.
Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
Third parties to ensure safety, security, or compliance with laws. We may 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 (such as 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.

4. The Security of Your Personal Information

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 Game or otherwise via the Internet; any transmission is at your own risk.

5. Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information

Retention Policy

MSDK Information MSDK Automatic Log In MSDK Log Out MSDK User Information MSDK Log In with Email MSDK Announcement Services MSDK Client Server Status MSDK Cloud Configuration Information TBDS SDK Information TGDP SDK Information Gvoice SDK Information GVoice Chat Data (real-time voice) GVoice chat data (voice message) GVoice chat data (for in-game safety): voice files GVoice Text chat data GVoice Device information and other technical information to enable voice chats and text chats IMUR Survey Information TSS Security SDK Information Mobile Game Anti-Cheating SDK Information Mobile Game Anti-Cheating Device Information & Identifiers Mobile Game Anti-Cheating SDK Information Cheat Tool Detection Information Data analytics/profiling information (Firebase)Information you provide to us (either directly or through a third party) (name, nickname, alias gender, compliance information, region location, friends list (facebook), friends list (as manually added by you), telephone number and/or email address, telephone number and email address, email address, telephone number, two-factor authentication information, data subject request information) Information generated as part of the Game (user id, battle information, ip address, device id, device information, routing information, chat data)

Stored for the duration of the CBT and deleted 30 days thereafter. You may also request for your data to be deleted at any time and we will do so within 30 days of the request.

6. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Game. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.

Access

You may 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.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.

Correction

You may have the right to correct personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account (“Settings” interface).

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Game account. 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 Game 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 Only

You may have a right to require that we 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). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at codek@levelinfinite.com or using the contact details set out below, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at codek@levelinfinite.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. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

We 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 Game for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.

7. Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: codek@levelinfinite.com

Mailing Address:

International Privacy & Data Protection Centre

30 Raffles Place #18-01

Singapore 048622

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

8. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

9. 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 Game, 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 2 (How We Process Your Personal Information);
sharing your personal information with third parties, companies within our corporate group, and a third party that acquires 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 3 (How We Store and Share Your Personal Information)