Effective as of: Juny 23, 2023
This Policy describes the personal information we collect from users of the Sites and Services and how we use and share such information. If you use our Sites and Services, you agree to the use of your personal information under this Policy. If you do not agree to this Policy, please do not use our Sites or Services.
The Sites and Services are operated by Program AR. (“we”, “us” or “our”).
Effective Date and Changes to this Policy
This Policy is current as of the Effective Date set forth above. Please note is subject to change and such changes to this Policy will be posted on the Sites and be effective immediately upon posting. However, in the case of changes that may affect you or in the case of significant changes, a period of 30 days will be provided before the changes take effect. Therefore, it is important that you review the Policy periodically. If we make any changes to this Policy that materially affect our practices, we will provide you with notice of such change (and will endeavor to do so in advance of its effectiveness) by highlighting the change on our Sites or, if you have an account with us, by providing notice to the email address associated with your account (for this reason you should make sure to update your account information promptly if it changes, by logging into your account and changing your user profile settings).
Information We Collect Directly From You. We respect your concerns regarding privacy. Our Sites and Services do not collect personally identifiable information about you unless you expressly provide such information. We may collect personal information in the following instances:
- If you register as a user of our Services, then we will ask for your email address And if you register as a user of our service using a platform operated by
Meta Platform, Inc(Hereinafter, Meta') or Apple, Inc(Hereinafter, 'Apple') or Riot Games Korea, Ltd.(Hereinafter, 'Riot') We collect the Unique-Identifiers that is linking with accounts of you registered with Meta or Apple or Riot. We use this information to identify you as a user and to communicate to you regarding the Services.
- There will be a profile established on the Sites relating to your game play for the particular game for which you have registered as a player. Please see the section entitled Information We Collect About Game Play for more details on what we collect.
- Our Sites and Services may allow users to post or upload information about themselves. Please note any information you post will be accessible to the public and to other users.
- If you contact us, we will collect your email address and the information you provide in order to respond to your inquiry.
Information We Collect About Gameplay. We collect information from your game sessions, such as kills, death, golds earned, experience points earned, and damages dealt to opponents from your profile. Such in-game data is directly provided to us by publishers, such as Riot Games. We may reprocess this data and provide additional information such as most played characters and their performance.
Information We Collect Automatically. We may automatically collect the following information about your use of our Sites or Services through cookies and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; your MAC address; your mobile device ID; your ADID(Advertising ID) and IDFA(ID for Advertisers); your Service usage and history; the length of time you visit our Sites or Services; and the referring URL, or the webpage that led you to our Sites or it includes, but is not limited to, etc.(Hereinafter, 'Automatically Collected Information') We may combine this information with other information that we have collected about you, including, where applicable, your E-mail Address. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
Purpose of use of personal information and personal information to be collected, etc
We use your information, including your personal information, for the following purposes:
- To provide our Sites and Services to you, to communicate with you about your use of our Sites and Services, to authenticate users, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.: your E-mail Address, the Unique-Identifiers that is linking with accounts of you registered with
Meta or Apple or Riot, the information you provided
- To process and transmit the content that you elect to share through the Sites and Services.: All the contents (posts) you posted.
- To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using our Sites or Services.: your game play profile in a specific game, game session information, and Automatically Collected Information, and Geolocation data such as country of residence.
- For marketing and promotional purposes. For example, we may use your email address to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you (you can unsubscribe from such communications at any time as noted in the Your Rights and Choices section). We may also use the information that we learn about you to assist us in advertising our Sites, Services and related services on third party websites: (In addition, you may at any time request suspension or deletion of your personal information that we use on third-party websites in accordance with relevant laws and regulations.): your E-mail Address, Automatically Collected Information.
- To better understand how users access and use our Sites and Services, both on an aggregated and individualized basis, in order to improve our Sites and Services and respond to user desires and preferences, and for other research and analytical purposes.: Automatically Collected Information.
We and our third party service providers may combine the Automatically Collected Information with other personal information we collect from you (and our third party service providers may do so on our behalf): Automatically Collected Information.
If the above personal information we collect is used outside of the above purpose or there is additional personal information to collect other than the above personal information, we will notify you and obtain your consent separately.
Sharing of Your Information
We may share your information, including personal information, as follows:
- Other Users. Any information that you post on our Services and any user names you use for game play and game play statistics through the Services will be made available to other users of the Services for purposes of evaluating your performance and selecting teammates.
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing the Sites and Services to you; however, if we do so, their use and disclosure of your personally identifiable information will be maintained by such affiliates and subsidiaries in accordance with this Policy.: However, we currently do not provide any information we collect from you to any of our affiliates or subsidiaries, and if we do provide the above information to our affiliates or subsidiaries in the future, we will indicate that affiliate or subsidiary in this Policy.
- Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. However, as of Juny 23, 2023 there are currently no third-party vendors, service providers, contractors, or agents who perform functions on our behalf.
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We may also disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
- To Protect Us and Others. We may also disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties and publicly for marketing, advertising, research or similar purposes.
Retention of Your Information
You may access, update, alter, or delete your user profile and account information by logging into your account and updating your profile settings.
Cookies and Other Tracking Mechanisms
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Sites and Services. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Sites. This allows us to process your online transactions and requests and to verify your identity, after you have logged in, as you move through our Sites.
- Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.
Do Not Track
We do not respond to Do Not Track (DNT) signals. However, some third-party websites track your browsing activity. When a user visits such a website, the website may be informed that the user does not wish to be tracked by setting the user's preferences in the user's web browser. You can enable or disable DNT by visiting your web browser's Preferences or Settings page.
Third Party Analytics
Third Party Advertising
These online advertising partners do not have access to or use your name, address, e-mail address, telephone number or other personally identifiable information from us, without your consent. They may, however, use persistent identifiers to anonymously track your Internet usage across other websites in their networks beyond these Sites. While we restrict their further use of such information, such third parties may, with sufficient data from other sources, be able to personally identify you, unknown to us.
Third-party ad serving companies and other unaffiliated advertisers also display advertisements on our Sites. As part of their service, they may place a separate cookie on your computer or utilize other data collection and tracking technologies, to collect information such as your IP address, browser type, the server your computer is logged onto, the geographic area associated with your server, and whether you responded to a particular advertisement. For a listing of the third party companies we may allow to place cookies to serve ads on the Sites, the detail is as in the link below
We do not control these third parties’ tracking technologies, how they may be used, or the information they may collect and we are not responsible for the privacy policies or the content of those third parties. Please visit the sites of those businesses at the links above to review their privacy policies. We may add or change the list of third party ad servers from time to time and we encourage you to check this section for changes. You can learn more about online advertising at www.aboutads.info/consumers.
No Use by Children
The Sites are not intended for use by children (age depending on the country where you reside). We will never knowingly collect information directly from children (age depending on the country where you reside) without verifiable parental consent. If you are a child (age depending on the country where you reside), you may not use the Sites or Services and please do not provide us with information of any kind whatsoever. If we become aware that a user is child (age depending on the country where you reside) and has submitted information to the website without verifiable parental consent, we will remove his or her information from our files and deactivate his or her account. If you have reason to believe that we may have accidentally received personal information from a child (age depending on the country where you reside), please contact us immediately at [email protected].
Location of Our Operation
The Sites and Services are operated from Argentina. If you choose to use the website or provide your information to us, your information will be transferred, processed and stored in Argentina. Your agreement to the terms of this Policy followed by your submission of information on the Sites and Services represents your agreement to this practice and transfer of your personal information to Argentina. In addition, our employees, contractors and affiliated organizations that process information for us as described above may be located in Argentina or in other countries outside of your home country; by using the Sites and Service, you consent to the international transfer of such information by us to such parties.
We have put in place appropriate security measures, including encryption and de-identification, 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. However, we will not be responsible for any problems that may arise of despite those safety measures and procedures, such as your negligence or problems on the internet. Please note that no data transmission over the internet is 100% secure, and that complete security of any information we collect and use therefore cannot be guaranteed.
Your Rights and Choices
Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and you have the 'right to be provided with information' from us pursuant to Article 12 GDPR, and to request access to, rectification, erasure, portability of your own personal information, and etc.
Therefore, if you want to make a request concerning your rights or if you have any other question, please contact us via email with the address specified in the “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 and, will provide information about the necessary documents you may need to exercise your rights. As follows, but not limited thereto;
- You have the right to information as to whether or not and to which extent we process which of your personal information.
- You have the right to rectification of any inaccurate personal information about you and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
- You have the right to the erasure of your personal information without undue delay unless we have a legitimate interest to keep the information, such as in the event we need the information to execute an agreement with you.
- You have the right to restrict the processing of your personal information, unless we have a legitimate interest to continue processing the information for the purpose in respect to which you requested the restriction. For example, you have the right to object to our processing of your personal information for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal information for this purpose. You have the right to receive your personal information from us in a structured, commonly used and machine-readable format – data portability. However, this right does not apply where it would adversely affect the rights and freedoms of others.
- You have the right to receive the personal data concerning you which you have provided to us, in a commonly used and machine-readable format (Data Portability).
- You have the right to object the processing of your data on grounds relating to your particular situation at any time.
- You have the right to withdraw your previously given consent at any time.
- For your protection, we will ask you for proof of your identity before making your personal data available to you. We may have to keep certain information required by law and/or for our own legitimate business purposes.
We will process your personal data for as long as necessary to provide the Services to you, to perform obligations under a contract with you or to comply with law. We will further process your data for the period of time where we have a legitimate interest to process your data, and this interest outweighs your interest or fundamental rights and freedoms, for the purposes of marketing and information of our business operations, or until you inform us according to your rights above. If and to the extent you have given consent to us to process your personal data, we will process the data in accordance with that consent, and we will delete the relevant information upon your withdrawal of consent.
Complaints Regarding Our Processing of Your Data
Links to Other Sites
Notice of Privacy Rights to California Residents
If you are a California Residents, for more information concerning your privacy rights, please follow this Notice
A. We establish and enforce this Notice for California Residents.
B. For California Residents, if this Notice Part conflicts with the other parts of our privacy, this Notice takes precedence.
C. The information we collect and the purpose of the collection.
- (1) 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 (“personal information”). We have collected these same categories of personal information from you over the past 12 months.
- (2) The information we collected about you and the purpose of its collection are as follows.
- Service operation and provision : Email Address, the Unique-Identifiers that is linking with accounts of you registered with Meta or Apple or Riot, An identifier such as account name, etc. provided by you (hereinafter 'Identifiers')
- Automatically Collected Information: your use of our Sites or Services through cookies and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; your MAC address; your mobile device ID; your ADID(Advertising ID) and IDFA(ID for Advertisers); your Service usage and history; the length of time you visit our Sites or Services; and the referring URL, or the webpage that led you to our Sites or it includes, but is not limited to, etc.(Hereinafter, 'Automatically Collected Information')
- Providing customized services, etc : Identifiers, Automatically Collected Information, Geographic location data of the country of residence, etc.
- The purpose of marketing and advertising, etc. : Email Address, Automatically Collected Information.
- Site and service improvement, response to user requests, other research and analysis purposes, etc. : Automatically Collected Information.
- Purpose of combining your "Automatically Collected Information" collected by us or our a third party service provider with other personal information collected from you : Automatically Collected Information
D. Personal information provided to a third-party
- (1) We can provide specific personal information to a third party for service provision and improvement, etc.
- (2) 2. We have disclosed or shared with a third party the following categories of personal information within the past 12 months. The details of disclosure or sharing of personal information to a third-party can be found in the link below.
- (3) However, we do not sell your personal information to a third party.
E. California Privacy Rights
- (1) 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 [email protected]. Please note that at least your email address will be required to submit a request. If you exercise your rights via email, you must specify the right(s) you wish to exercise.
- (2) We will verify your identity and respond to your request within 45 calendar days. If necessary, we can take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, provided that we notify you to explain the reason for the delay.
- a. Right to Access: You have the right to request the following information 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
- Categories of the sources from which personal information was collected
- Business or commercial purposes for which personal information is collected
- Categories of the personal information that was disclosed for a business purpose or sold during the past 12 months, and categories of third parties to whom the information was disclosed or sold.
- b. Right to Request Deletion: You have the right to request that the personal information collected from you be deleted.
- c. Right to Opt-Out of Personal Information Sales: You have the right to “opt out” by requesting that your personal information not be sold in any form. However, we do not sell personal information.
- d. Right to Non-Discrimination: You have the right to not be discriminated against for exercising your privacy rights under the CCPA(including CPRA)
- e. Rights for California Minors: Minors under the age of 18 have the right to request the deletion of and/or obtain information posted on websites such as forums or bulletin boards.
- f. Shine the Light: You have the right to request the categories of the personal information that we disclosed to third parties in the last year for direct marketing purposes and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for direct marketing purposes."
- a. Right to Access: You have the right to request the following information up to two times within a 12-month period.
F. 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(including CPRA).