Privacy Policy

Glohow Holdings Pte. Ltd. (“Company”) respects your privacy and personal information, and observes the “Privacy Agreement” etc. The Company provides this Privacy Policy to inform you of the purpose of collecting your personal information, how we make use of it as well as what measures we take to protect your personal information.

This Privacy Policy includes the following content.

Article. 1 (The Elements of Personal Information we may collect and the collecting method)

1. The Company will only collect personal information that is essential for the user to access the service. The type of information collected is as listed below.

1.1 Upon initial access to the service
- Required: Name or Nickname, Platform (Google, Apple, Game Center, Facebook) unique serial number for user identification afforded by the user’s platform operator, user’s mobile ID number (including the mobile device ID or UDID)
1.2 Upon accessing user support services
- Required: Email address, Nickname or another name which the user has agreed to show
1.3 Upon billing/refunding products
- Optional: Email address, confirmation of purchase, screenshot of digital receipt with Order ID number, additional information required for proof of purchase
1.4 Upon sending promotional notifications for events
- Optional: Email address, mobile phone number
1.5 Upon sending event rewards and prize money
- Required: Name, address, contact information and email address
1.6 Upon participating in a community event
- Optional: Name, address, contact information or email address

- Required: Nickname, Unique Identification Number of user’s account (Game ID or UID), Server name

2. Upon using the service, the company may collect your personal information as below to analyze service usage data, provide personalized advertisement services following information may be produced and collected.

- User Status Information, Cookies, Date and Time of User’s Visit to the company, Record of Service Use, Record of Abnormal behaviors, etc.

3. The company does not collect any sensitive and private information (Race, Personal Belief, Philosophy, Political Tendency, Criminal Record, Medical Record, etc.)

4. The company collects user’s personal information in the following ways.

Article. 2 (Collecting Personal Information and the Use)

1. Basic function to encounter the service.

- We collect and save the mobile ID Number (including the mobile device ID or UDID) by checking the Unique Identification Number of the user's account for the purpose of verifying the user’s account.

2. Fulfillment of contract as a game service provider and balancing the Charging and Setting.

- We provide free/premium contents, purchased goods, age authentication (Japan only), finalization of what is bought and paid accordingly, balanced charges and collection of the uncollected charges.

3. User Management

- We require User-Verification before the access to the account of the game service, Individual Identification, Prevention of Mod-program and Abusing any content of the game, Approval of Joining the game service, Limits to creating multiple accounts, Preservation of records of Personal information for dispute conciliation, handling of complaints and civil affairs, and conveyance of notification.

4. Development of New Service and Marketing/ Advertisement.

- We may refer to the user's personal information not only to develop new contents but also provide customized services. Our service is based on statistical in-game data which can be used for advertising purposes. Also, the validation of service is confirmed before the release. The personal information can be a source to be referenced to use in creating any events or advertisements for users to participate. Access frequency of users and other types of similar information can be used as statistical information to research the state of service use.

Article. 3 (Sharing of User’s Information)

1. We use personal information of users in the boundary of Article 2 and there would be no situation where we over-use such information without the consent of users or reveal it to 3rd person. However, exceptions may be aroused as

- We gain the user's consent.
- We process the personal information as illegible to protect the privacy of individuals for the purpose of statistical data use.
- We meet the situation where we have to accept the request of investigating agencies to follow certain procedures.

2. In the case that it is inevitable for affiliate companies to provide user’s information to a limited extent, we share or provide such information after having the consent from users about to whom and what information we are sharing with in what purpose and for the purpose of providing various kinds of service.

Article. 4 (Charges of Personal Information and Transfer to Other Countries)

1. In principle, the Company does not entrust other companies with the handling of personal information of users.

2. Despite Article 1, the company can entrust other companies for better managing and handling some of the personal information much smoother as follows. Also, it can be safely managed in accordance with the privacy laws.

- Contractor

Business contents

Period

Contractor

Business contents

Period

3. The Company will not transfer the personal information of users to outside the country without the consent of the user.

Article. 5 (Period of possessing and using personal information)

In principle, the personal information of the user is destroyed without delay when the purpose of collecting and using the personal information is achieved. However, the following information will be kept for the period specified below for the following reasons.

1. In order to prevent fraudulent use in accordance with the internal policy of the company, the personal information will be kept for 7 days after the application for membership withdrawal. After this period, the user's personal information will be completely deleted.

2. In the case of investigations or investigations related to the violation of related laws and regulations, the information of the users will be preserved until the end of investigation.

3. If there is a claim-obligation relationship between the company and the user, the personal information of the user is retained until the settlement of the relationship is resolved or complete.

4. When it is necessary to preserve the information according to the related laws and regulations such as commercial law, consumer protection law in e-commerce, etc, the company keeps user information for a certain period determined by related laws and regulations. In this case, the company will only use the information it keeps for the purpose of storing it, and the period of preservation is as follows.

- Records on contract or withdrawal of subscription (Reason for preservation: Consumer Protection Act on Electronic Commerce, etc., Preservation period: 5 years)
- Records on provision of goods and any information about the payments (Reason for Preservation: Consumer Protection Act on Electronic Commerce, etc. Preservation period: 5 years)
- Records on complaints or disputes with consumers (Reason for Preservation: Consumer Protection Act on Electronic Commerce, etc. Preservation period: 3 years)
- Date and time of telecommunication, open?end time, user id, frequency of use (Reason for Preservation: Communication Confidentiality Protection Act, Preservation period: 1 year)
- Records on displaying and advertising (Reason for Preservation: Consumer Protection Act on Electronic Commerce, etc. Preservation period: 6 months)
- Records on the visiting the company (Reason for Preservation: Communication Confidentiality Protection Act, preservation period: 3 months)

5. Personal information submitted and registered by a job applicant via the Company’s recruitment website to the Talent Pool shall be preserved for 2 years from when the application was submitted.

6. Personal information registered by the applicant on the application form shall be preserved for 2 months from when the Company offers a job to the job applicant. However, the personal information shall be deleted should the applicant request that the data be deleted.

Article. 6 (Dormant Accounts)

1. The company will switch a customer’s account or character to a dormant account if the user does not have access records within the game for 12 months or more after the last access date in order to prevent the user’s account or character from being used for unfair purposes and to protect personal information.

2. If the customer’s account is switched to a dormant account, only the minimum amount of information needed for restoration and normalization will remain. Personal information will be stored separately in order to fulfill the goals required by the law.

3. As long as the maximum retention period has not elapsed more than a year after being switched to a dormant account, the user will be able to restore his/her account through means such as accessing the game. However, the dormant account will be deleted if the following requirements are met.

3.1 In case the account or character log-in history hasn’t been existed for a year or more after being switched to a dormant account
3.2 In case there is no paid item or there is no paid item that has remaining period in the account

Article. 7 (Procedures and Methods of Destroying Personal Information)

In principle, the personal information of a user is destroyed without delay when the purpose of collecting and using the personal information is achieved. The procedure and method are as follows.

1. Destruction procedure

- The information entered by the user to join the service is transferred to a separate DB after the purpose is accomplished and stored for a certain period of time according to the internal policy and other related laws and regulations (see the period of possession and use).
- Personal information will not be used for any other purpose other than that held by law.

2. Destruction method of Personal information

- Paperwork is destroyed by crusher or by incineration.
- Any form of electronic file is deleted using a technical method that cannot play the record.

Article. 8 (Rights of Users and Legal Guardians, and How to Act)

1. Users and legal guardians can view or modify personal information of users who are registered at any time, or users who are under 14 years old, through platform operators or the open market operators, to request termination of services through logging- out and deleting process of applications.

2. In order for the user to check his / her personal information that is not owned by the company, the company shall compare the subscription history that the company has to the other personal information of the user’s platform operator or the open market operator providing the service. match them so that the company can verify the user’s identification.

3. The Company shall not use or provide personal information until the correction is completed if the user requests for correction of errors in the personal information. In addition, if wrong personal information has already been provided to a third party, the Company will promptly notify the third party of the result of the correction and allow the correction to be made.

4. The Company treats personal information that has been revoked or deleted at the request of the user or legal guardian as specified in Article 5, "Period of possessing and using personal information", and is prohibited from being viewed or used for other purposes.

5. Your California Privacy Rights California Civil Code Section 1798 allows California residents to have the right to request

(a) information identifying any third party to whom the company may have disclosed (within the previous calendar year) his/her personal information for that third party’s direct marketing purposes; and
(b) a description of the categories of personal information disclosed. If you are a California resident and wish to obtain such information, please send a request email to policy@glohow.com

6. Privacy Rights for California Minors

- California residents under the age of 18 having a registered account, have the right to request removal of any content or information that he or she posted anywhere within our Services, such as public forums or message boards in our Websites or Applications. To request removal of such information, you can contact the company at policy@glohow.com stating that you reside in California.
- Please be aware that the removal of your information or content may not be complete or comprehensive, and residual copies of such removed information or content may remain on our servers. In addition, we are not obligated to remove any posted content or information that has been copied or reposted by a third party, that has been rendered anonymous, or that we are required to keep by law.

Article. 9 (Technical and administrative protection measures of personal information)

The Company takes the following technical and administrative measures to ensure the safety of personal information in order to prevent personal information from being lost, stolen, leaked, altered or damaged. However, the Company cannot guarantee 100% protection for the loss or corruption of the above personal information due to the process of transmission of the user's personal information or the attack by Hackers and other 3rd entity.

1. Measures against hacking

- The company is doing its best to prevent personal information from being leaked or damaged by hacking or computer virus. In order to prevent damage to personal information, we backup the data from time to time to prevent personal information or data from being leaked or damaged, and we can securely transmit personal information over the network through encrypted communication. We use intrusion prevention systems to control unauthorized access from the outside, and try to have all possible technical devices to ensure security in other systems.

2. Minimization of the staff handling such information and the training.

- The staff who handle company's personal information is limited to the person in charge and a separate password is given to them to update them regularly. We constantly emphasize the importance of compliance with Glohow's privacy policy through regular training.

3. Establishment and enforcement of internal management plan

- The Company has established and implemented an internal management plan for the safe management of personal information.

4. Operation of personal information protection organization

- The Company is responsible for confirming compliance with the Glohow Privacy Policy and the person in charge through the in-house personal information protection organization, so that if any problem is found, it can be corrected immediately. However, the Company does not take any responsibility for any problems caused by leakage of personal information for reasons such as user's negligence. The Company still is in charge of the issues aroused by the company's intentional or material negligence.

Article. 10 (Chief Manager of Personal Information)

In order to protect your personal information and to handle relevant complaints, the Company has designated a Chief Manager of Personal Information and Management Team as described below.

[Chief Manager of Personal information Protection]

[Personal information Protection Management Team]

Article. 11 (Installation and Operation of Automatic Information Collection Technologies and How to Disable Them)

1. Website Cookies

1.1 The Company uses cookies in order to provide a more convenient website environment to the users. The user may disable cookies if they choose to do so.

1.2 ‘Cookies’ are a text file that a webserver of a specific website will send to the user’s web browser and will identify the user’s access records, usage pattern etc.

1.3 Should the user choose to disable Cookies, the user may do so by changing their web browser settings.

Internet Explorer

Chrome

Microsoft Edge

Please make sure to check the settings relevant for each internet browser.

2. Advertising Identifier (ADID, IDFA)

2.1 The Company shall utilize an Advertising Identifier (Advertising ID) in order to analyze the user’s mobile application usage, access records etc. in order to provide personalized advertisement services and the user shall have the option to refuse providing this information.
2.2 “Advertising Identifier” is the most basic unique unit used by Google and Apple in order to analyze the user’s behavior when using mobile applications. The Advertising ID assigned by the Google Play Store is ADID and the Advertising ID assigned by the Apple App Store is IDFA.
2.3 If the user does not wish to allow their Advertising ID to be utilized, they may disable the usage in accordance with the operating system of their mobile device.
3. Google Analytics
- 3.1 The Company uses the Log Analysis Tool, Google Analytics, for the improvisation of services with the objective of using its services and statistical analysis. The user shall have the option to refuse providing this information.
- 3.2 If the user does not wish to allow log analysis with Google Analytics, he/she may disable it by installing additional functions of the Google Analytics through the link below. ※ Notice regarding Google Analytics Opt-out Browser Add-on
  - 1) Website Cookies
    - 1-1 The Company uses cookies to provide a more convenient website environment to the users. The user may disable cookies if they choose to do so.
    - 1-2 “Cookies” are text files that a webserver of a specific website sends to the user’s web browser to identify the user’s access records, usage patterns, etc.
    - 1-3 Should the user choose to disable Cookies, the user may do so by changing their web browser settings. Below are the instructions for common browsers:
    - 1-4 Disabling cookies may impact the functionality of certain services provided on the website.
  - 2) Advertising Identifier (ADID, IDFA)
    - 2-1 The Company utilizes an Advertising Identifier (Advertising ID) to analyze the user’s mobile application usage, access records, etc., to provide personalized advertisement services. The user has the option to refuse providing this information.
    - 2-2 “Advertising Identifier” is the basic unique unit used by Google and Apple to analyze the user’s behavior when using mobile applications. The Advertising ID assigned by the Google Play Store is ADID, and the Advertising ID assigned by the Apple App Store is IDFA.
    - 2-3 If the user does not wish to allow their Advertising ID to be utilized, they may disable its usage according to the operating system of their mobile device:
  - 3) Google Analytics
    - 3-1 The Company uses the Log Analysis Tool, Google Analytics, to improve services with the objective of service usage and statistical analysis. The user has the option to refuse providing this information.
    - 3-2 If the user does not wish to allow log analysis with Google Analytics, they may disable it by installing additional functions of the Google Analytics through the link below. Google Analytics Opt-out Browser Add-on
    - 3-3 Users can manage their preferences related to Google Analytics directly through their browser settings or by using the opt-out add-on provided by Google.
  - 4) Additional Information Collection Technologies
    - 4-1 The Company may use other automatic information collection technologies similar to cookies and advertising identifiers to gather user data for improving services and providing personalized experiences.
    - 4-2 Users will be informed about the use of any such technologies and given the option to disable them if preferred.
  - 5) User Control Over Information Collection
    - 5-1 Users have the right to control the information collected by these technologies and can exercise their preferences through the provided settings and options.
    - 5-2 The Company will provide clear instructions and support to users who wish to manage or disable the automatic information collection technologies.
Article. 12 (Obligation of Notification)

The Company will notify users of any changes to this Privacy Policy through the service website (or individual notice) at least 7 days before the changes take effect. However, if there is a significant change in user rights, such as the collection and use of personal information or the provision to third parties, we will notify users at least 30 days in advance.
Contact Information For any questions or concerns about this Privacy Policy or the Company’s data practices, please contact us at:
This Privacy Policy will be effective from the date of June 1st, 2024.