[Table of Contents]

1. Introduction

2. What Information Do We Collect

3. How We Use Your Information

4. How We Share Your Information

5. Cookies and Related Technologies

6. International Data Transfers

7. Retaining and Deleting Personal Information

8. Our Policy Concerning Children

9. Links and Third-Party Services

10. Security of Your Information

11. Your Privacy Rights

12. Amendments

13. Contact Us

Appendix. SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC

1. Introduction

KRAFTON, Inc. and/or its affiliates (“we”, “Company” or “us”) keep and process information about you (“you”, “user”, or “player”). We comply with all applicable laws related to personal information and strive to protect the rights of individual players by adopting this Privacy Policy (“Policy”) in accordance with relevant laws and regulations. This Privacy Policy describes how we collect and use personal information about you during and after your relationship with us. We provide a various video games and game services including “Project ZETA”, the official site and service related to the Game (i.e. survey, or customer service) (“Service(s)”) to players.

We will occasionally update this, Policy. When we do, we will revise the effective date above. While we will periodically inform you of this Policy or any material changes to it, your continued use of our Services after such changes means you accept the Policy as revised. We encourage you to periodically review this Policy to stay informed about how we collect and process your personal information. From time to time, we may ask you to confirm your acceptance of this Policy when we offer our Services.

2. What Information Do We Collect

We will collect the following categories of information that may directly or indirectly identify or describe you or your device or information that may be reasonably capable of being associated with or reasonably linked to you or your device. The information you provide to us may differ depending on the circumstances. For example, these include:

a. Identifiers, such as SteamID64, Platform ID, Discord ID, nickname, IP address, email address, gender, language, etc.,

b. Internet or other electronic network activity information, such as browsing behavior while using our Services (i.e. device model, OS version, MAC address, device ID, etc.), and

c. Game information, such as information about crash report and system activity details (game setting, play date/time, etc.).

We use this data to operate and improve our Services. Some of this information is collected through our use of cookies and related online tools/technologies. See our “Cookies and Related Technologies” section below for more information.

3. How We Use Your Information

We use the collected information for a variety of purposes, primarily, to provide the Services to users like you and to improve the quality of our Services. These include:

1) To operate and provide our Services;

2) To develop new services, improve the quality of our Services, and fix bugs;

3) To detect and act upon the illegal or unauthorized use of our Services;

4) To manage inquiries and requests from you;

5) To provide advertising information and other information on marketing, and conduct promotional events and surveys;

6) To track usage patterns, analyze trends of users, and calculate statistics on Services;

7) To prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, cheating, hacking or criminal activity; and

8) To comply with and enforce legal requirements, agreements, and policies.

Most of the time, our processing of your personal information is necessary to respond to you or process your request. We may also process your information to comply with a relevant legal obligation. From time to time, we may ask for your consent to use your information for specific reasons. Where consent was provided and is required, you may withdraw your consent at any time by contacting us at the address provided in this Policy.

4. How We Share Your Information

We share certain personal information with third parties to provide our Services to you, including service providers that process personal information on behalf of us to provide our Services to you, like customer support and to manage our community. Some examples of these third parties are provided below.

1) cloud computing service providers to provide cloud storage services;

2) marketing platforms and providers of analytics services relating to user behavior, in order to tailor the Service and to conduct marketing activities;

3) online survey service providers in order to improve Services;

4) customer service providers to answer users’ inquiries; and

5) third-party platform providers to provide game.

We may share your information where such disclosure is essential to comply with a legal obligation or a lawful data access request, pursuant to a merger or acquisition, or where you have otherwise provided your consent or at your direction.

5. Cookies and Related Technologies

We use cookies, and other technologies to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes. Approved third parties may also set cookies and related technologies when you use our Services.

1) Cookies

Cookies are small files downloaded to your computer (if your browser is enabled to accept cookies) to track movements within websites and to customize your experience within the website. Most Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of our websites may not function properly.

We do not control cookies in third party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. Ads appearing on our websites may be delivered to you by third-party advertising companies. These companies may use information about your visits to our websites in order to provide advertisements to you and other sites about goods and services that may be of interest to you.

2) Website/Apps Analytics

We use analysis services on this site or apps to allow us to record information on the use of this Site and to constantly improve our offering.

This Site and the App uses Google® Analytics and related technologies, analysis services offered by Google Inc. (“Google”). We may use the following advertising functions of Google® Analytics and collect personal information as provided by Google, and you may withdraw your consent by deactivating such functions in Google’s advertising settings: Remarketing by using Google® Analytics; Google® Display Network Exposure Report; Google® Analytics Demographics and Interests Report; and Integrated service allowing the collection of data through Google® Analytics by using advertising cookies and anonymous IDs. More information about Google’s own privacy policy can be found at https://www.google.com/policies/privacy. If you wish to opt-out from your information or data being used by Google Analytics, you may download the Google Analytics Opt-out Browser Add-on available here: https://tools.google.com/dlpage/gaoptout

6. International Data Transfers

Your personal information will be stored and processed on our secure servers. The access to your personal information is limited to our employees’, agents and contracted third party, who are bound by strict confidentiality agreements and have access only on a business need to know basis. No one can access your personal information without our approval. However, we may electronically transfer your data, secured through multiple layers of security, communicated using leading encrypted technologies, to contracted third party service providers, who may be in different country or regions to operate the game service and/or to meet any legal requirements. The legal basis for such processing is compliance with a legal obligation to which we are subject to or are legitimate interests, such as exercise or defense of legal claims.

7. Retaining and Deleting Personal Information

In principle, we will remove your personal information withot delay after the purpose of collecting personal information is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using technical measures in a way that the information cannot be reproduced. However, we may retain your personal information even after you have closed your account with us or we have ceased providing Services to you, if retention of your personal information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Policy or any other agreement we may have with a user.

8. Our Policy Concerning Children

We do not knowingly collect, use or share any sensitive and personal information about underage users(age rating depends on the country where you reside) without verifiable parental consent or as permitted by law. If you are a parent or guardian and you believe your child has provided us with the information, you can contact us and request your child's information to be deleted from our system.

9. Links and Third-Party Services

If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave our website and go to the website you selected. Because we cannot control the activities of third parties, we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to our Services, you should consult that site’s privacy policy before providing any personal information.

10. Security of Your Information

We have put in place appropriate security measures to prevent your personal information from being accidentally leaked, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, etc. who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have put in place safety procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

11. Your Privacy Rights

Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information. To make a request concerning your rights or if you have any other question, please contact us by sending an email to the address specified in the “13. Contact Us” section. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

12. Amendments

We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Site. You will be deemed to have accepted such amendments by continuing to use the Service, so please review it frequently.

13. Contact Us

If you have any questions about this Policy, or your dealings with our services, please contact us by using one of the following communication channels.

- Email Address: zeta_support@krafton.com or privacy@krafton.com

Appendix. SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC

This portion of our Policy applies to residents of the jurisdictions indicated below. In the event of a conflict between the Policy and this section, this section supersedes and controls.

1. United States

1) Privacy Rights for United States Users

Several U.S. states provide their residents with rights to:

a. Confirm whether we process their personal information;

b. Access and delete certain personal information;

c. Take their data from one location to another (data portability);

d. Opt-out of personal data processing for targeted advertising and sales;

e. Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose;

f. Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights submit a request form send us an email to zeta_support@krafton.com, or privacy@krafton.com. To appeal a decision regarding a consumer rights request, follow the instructions in the written notice we will provide to you.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: (e-mail: zeta_support@krafton.com, or privacy@krafton.com). However, please know we do not currently sell data triggering that statute’s opt-out requirements.

2) California

If you are a California resident, you may have additional rights as detailed below. Within the preceding 12 months, we have collected or disclosed the following categories of personal information about you:

a. Identifiers, such as SteamID64, Platform ID, Discord ID, nickname, email address, etc.

- How collected: When you access or play our Game or Services, we collect this directly from you.

- How disclosed: With our affiliates and service providers (e.g., cloud storage service provider, marketing platform service provider, online survey service provider).

b. Characteristics of protected classifications such as gender, language, nationality, etc.

- How collected: When you access or play our Games or Services, we collect this directly from you.

- How disclosed: With our affiliates and service providers (e.g., cloud storage service provider, marketing platform service provider, online survey service provider).

c. Internet or other similar network activity, such as browsing behavior while using our Games and Services (e.g., device model, OS version, MAC address, device ID, game information, etc.)

- How collected: When you access or play our Games or Services, we collect this automatically.

- How disclosed: With our affiliates and service providers (e.g., cloud storage service provider, marketing platform service provider, online survey service provider).

d. Geolocation information obtained by IP address.

- How collected: When you access or play our Games or Services, we collect this automatically.

- How disclosed: With our affiliates and service providers (e.g., cloud storage service provider, marketing platform service provider, online survey service provider).

We determine the retention period for each of the categories of personal information listed above based on our business or commercial purposes for obtaining the information, our legal or regulatory requirements applicable to such information, and in relation to litigation or to protect our rights.

- Your California Privacy Rights

You may exercise the following rights at any point in time in connection with your personal information. To exercise such rights, please email us at zeta_support@krafton.com, or privacy@krafton.com. Please note that at least your email address will be required to submit a request, and additional information may be required so we can verify you. If you exercise your rights via email, you must specify the right(s) you wish to exercise.

We will verify your identity and respond to your request within 45 calendar days. If necessary, we may take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, in which case we will notify you to explain the reason for the delay.

a. Right to Know & Right to Access

You have the right to request the following information from us up to two times within a 12-month period:

- the categories of personal information that we have collected from you over the past 12 months, and the specific pieces of personal information we have collected from you;

- the categories of sources from which personal information was collected;

- the business or commercial purposes for which personal information is collected;

- the categories of personal information that we have disclosed for a business purpose or sold during the past 12 months, and

- the categories of third parties to whom the information was disclosed or sold (if applicable).

b. Right to Delete

You have the right to request that the personal information collected from you be deleted.

c. Right to Correct

You have the right to correct your personal information. You can edit your personal information via the in-game “Setting” menu or email to zeta_support@krafton.com, or privacy@krafton.com.

d. Right to Non-Discrimination

You have the right not to be discriminated against for exercising these privacy rights.

e. Right to opt-out of Selling and Sharing

You have the right to opt-out of the selling and sharing of your personal information as defined by California law by requesting that your personal information not be sold or shared in any form. With respect to targeted advertising, you can control the sharing of your personal information for targeted advertising purposes through our website by opting out from advertising cookies through the cookie banner.

HOWEVER, WE HAVE NOT “SOLD” PERSONAL INFORMATION TO THIRD PARTIES AS THAT TERMS IS DEFINED BY THE CCPA WITHIN THE PAST 12 MONTHS. ALSO, WE HAVE NOT “SHARED” PERSONAL INFORMATION WITH THIRD PARTIES FOR THE PURPOSE OF CROSS-CONTEXT BEHAVIORAL ADVERTISING.

f. Rights for California Minors

Minors under the age of 16 have the right to request the deletion, correction or copies of information publicly posted by you, such as on forums or bulletin boards.

g. Shine the Light

You have the right to request the categories of the personal information that we disclosed to third parties for their direct marketing purposes during the past 12 months and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for their direct marketing purposes.

h. Limit Use and/or Disclosure of Sensitive Personal Information

You have the right to limit our use of your sensitive personal information. However, WE DO NOT USE YOUR SENSITIVE PERSONAL INFORMATION for purposes that require us to offer this limitation option. If we collect your sensitive personal information, we will get your consent.

- Authorized Agent

You may designate another person or entity (“authorized agent”) to act on your behalf in connection with your request for rights that are guaranteed by the CCPA. An authorized agent is a natural person or business entity registered with the Secretary of State to conduct business in California that you have authorized to act of your behalf to make a request to know or to delete.

In order to use an authorized agent for your request, we require that you provide signed permission to your agent. Your authorized agent can submit a request to know or delete by sending an email to zeta_support@krafton.com, or privacy@krafton.com. If you contact us, we can offer you an authorized form for your agent to submit.

The above requirement does not apply should your agent have power of attorney pursuant to Probate Code sections 4000 to 4465. Please note that we may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Under the CCPA, your agent is responsible for implementing and maintaining reasonable security procedures and practices to protect your information and use your personal information only for the purpose of fulfilling your request.

If you have any questions about this Policy, or about exercising your rights described above, you can contact us by email at zeta_support@krafton.com, or privacy@krafton.com.