Ring of Elysium Privacy Policy

Last Updated: April 19, 2019

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

Here is a summary of the information contained in this privacy policy. This summary is to help you navigate the privacy policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we need 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. We will also process some information when you use the Game (e.g., to make sure your progress is saved) and when you buy items (e.g., to ensure you get the purchased content). If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns.

How will we use your information?

We use your information to provide the many functions and services that comprise the Game. We do not share your information with any third parties, except where we need to in order to provide the service (e.g., use local cloud providers or to back up your data; using our affiliates around the world to help us to deliver the Game) or we are instructed to by a court, authority or compelled by law.

Who do we share your information with?

We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data). When we use a third party, we only do this to process or store your information for the purposes described in this privacy policy. We also have affiliates around the world who help us deliver the Game and we may be required by a court or legal obligation to disclose certain information in some circumstances.

Where do we process your information?

Our servers are located in Hong Kong, the United States, Singapore and Germany. Our support, engineering and other teams are located in our offices around the world (including the United States and the People’s Republic of China).

How long do we keep hold of your information?

We generally retain your information for the period during which you maintain an account for this Game after which time your data is deleted (as further described in this privacy policy), unless otherwise required by applicable laws.

How can I exercise my rights over my information?

Depending on where you live, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data.

How to get in touch with us

If you have any questions about anything in this policy, or want to exercise any rights you may have, please contact us at ROE_DPO@tencent.com .

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will update the policy here.

Contact Information

Data Controller: TCH Scarlet Limited

Email: You can contact the data controller at ROE_DPO@tencent.com. 

 


Welcome to Ring of Elysium!

This privacy policy explains the when, how and why when it comes to processing of your personal information in connection with the Game, and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

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 accepting our rules regarding your personal information as described in this privacy policy.

 

This Game has been developed by the Tencent group (“we”, “us”, “our”). For the purpose of EU data protection laws, the data controller of your personal information in relation to this Game is TCH Scarlet Limited, which is an Irish company within the Tencent group. The registered address of TCH Scarlet Limited is Harcourt Center, Block 3, Harcourt Road, Dublin 2, Republic of Ireland. Our data protection officer can be contacted at ROE_DPO@tencent.com.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at ROE_DPO@tencent.com.

The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information” below.

The following is a high level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party). 

 

This Game is hosted on the Steam platform operated by Valve Corporation (referred to as “Steam”), which is not part of the Tencent group. When you register for this Game, Steam generates a Steam ID for your account and we receive this from them.

 

2. Information about you generated as part of the Game (and its in-Game services)

 

We automatically collect certain data from you so that we can provide you with the many functions and services that comprise the Game. This includes your account ID (a unique number that we generate), your IP address and information about your device. This Game also incorporates a security feature to help us maintain a fair playing experience for all players. This security feature collects information about the device, network and system on which you are playing this Game.

 

When you play the Game you also generate information personal to your gameplay, including statistics and your virtual character. We collect and store this information, as well as log data that records how you use the Game.

 

We also collect and store your data if you choose to use certain additional features of the Game including:

·       If you want to conduct any transactions within the Game (e.g., buying items via in-game purchase).

·       If you enable the chat feature, we process your chats and chat log data (e.g. time of chat and who you chat with) in order to allow you to communicate with other users.

·       If you reach out to our support team. In order to establish what is wrong, and how to correct it, we will need to collect your email and information about your device, network and system. We may also report back to you using the email you provided when contacting our support team.

 

Children

If you are under the age specified below (for the country you live in) then unfortunately you are not permitted to use the Game.

 

Country/region

Minimum age

Brazil

18

European Economic Area

(all EU countries, Iceland, Liechtenstein and Norway)

16

Japan

16

Republic of Korea

14

Russia

14

Switzerland

16

All other countries

13

 

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 this age, please contact us at ROE_DPO@tencent.com and we will delete such information.

How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the European Economic Area (“EEA”), it also identifies the legal basis under which we process your data.

Personal Information

Use

Legal Basis (only relevant if you are located in the EEA)

Game

Information you provide to us (either directly or through a third party)

Steam ID

We receive your Steam ID from Steam when you create your account for this Game.

Necessary to perform our contract with you to provide this Game.

Information generated as part of the Game (and its in-Game services)

Account ID

We use your account ID to set up your account, improve our services and provide operational support.

Necessary to perform our contract with you to provide this Game.

IP Address

We use your IP Address to provide the Game to you, improve our services and provide operational support.

Necessary to perform our contract with you to provide this Game.

Advertising ID

We use your advertising ID to improve our services and provide operational support.

It is in our legitimate interests to use this information to enhance performance and management of this Game.

Device information: hardware specifications (including OS version), network information, information about your internet or WiFi connection, country code, and application version

We use your device information to maintain your account and the Game services on different devices.

Necessary to perform our contract with you to provide this Game.

Security-related information: basic hardware information, operating system information, machine codes for security authentication, user account information, network information, information of files, processes, modules, memory and driver which is related to the game running, user behaviour and status that may be related to plug-in use, image files, memory image and shellcode which is related to the game running, system API calls, method calls, system procedures and related data of active windows, information on in-game modules, game screenshots, external programs attempting to access private data which belongs to process of game application.

We use this information:

·     for security purposes, including to detect cheating behaviours;

·     to provide a fair Game environment; and

·     to solve Game crash and to improve our services.

It is in our legitimate interests to use this information for security purposes.

Transaction information: Steam ID, country/region code, currency code, in-game language code, order ID, IP address, price and item information

We receive this information from Steam. Of this information, we store the time, order ID, IP address, price and item information of in-Game purchases.

We use this information to facilitate your payment and to maintain a record of your purchase history.

Necessary to perform our contract with you to provide this Game and to enable purchases of in-Game items.

Chat log data

We use this information to enable your communications with other users.

Necessary to perform our contract with you to provide this Game if you enable chat services.

Customer support information: ticket ID, information provided by you when contacting our customer support team which may include information about your device, network and system, your email address

We use this information to:

·        improve our services;

·        provide troubleshooting, such as addressing and remediating technical issues and bugs.

Necessary to perform our contract with you to provide and support this Game.

Game data: account ID, nickname, character ID, details about your virtual character, server, channel, and Game play statistics such as your level, characters, score/s

We use this information to provide you with feedback and information about your Game play and progress, and to save your Game data for future play.

Necessary to perform our contract with you to provide this Game.

Game log data: account log in and log out times and access to the Game room

We use this information to:

·        maintain a record of log-in and actions of your account;

·        improve our services, including the functionality of this Game; and

·        for troubleshooting purposes.

Necessary to perform our contract with you to provide this Game and retain your record of progress.

We may collect other personal information from you from time to time for specific reasons (such as a promotion in your country). When this happens, we will provide more information on any specific changes to the way we process that personal information that might differ to this privacy policy prior to collecting or processing any additional information. In some cases, that information may be shared with us with your consent – and if that is the case, we will provide you with further information on how we process that information and your rights.

How We Store and Share Your Personal Information

The Tencent group operates around the world. Pursuant to our contract with you to provide you with this Game, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers for this Game are located in:

·       the United States;

·       Hong Kong;

·       Singapore; and

·       Germany.

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 this Game, including providers of cloud services that process information identified in this privacy policy on their servers for the purpose of providing this Game. All third party service providers are prohibited from using your personal information for any purpose other than providing us with their services.

·       Companies within the Tencent corporate group who process your personal information in order to operate this Game. All related group companies may only use your personal information in accordance with this privacy policy.

Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. 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 do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

Data Retention

Personal Information

Retention Policy

Steam ID.

Account ID.

IP Address.

Advertising ID.

Device information*.

Transaction information*.

Chat log data*.

Customer support information*.

Game data*.

Game log data*.

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for 30 days.

Security-related information*.

We generally retain this data for no longer than 90 days with the exceptions listed below. Upon a deletion request, we will delete the data within 30 days except where they relate to confirmed malicious activities.

·       File sample collection and memory sample collection related to confirmed malicious activities: up to 10 years

·       In-game process information and system information: up to 10 years.

·       Security authentication: up to 5 years.

 

*Full description of data is set out in the section “How We Use Your Personal Information” above.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

Your Rights

Some countries’ laws grant specific rights to users of this Game, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in the European Economic Area.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Brazil and Canada.

You 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). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at ROE_DPO@tencent.com.

Access

You 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 Game account. If you believe we hold any other personal information about you, please contact us at ROE_DPO@tencent.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. You have the right to receive this personal information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer it to another party, with certain exceptions. We will provide further information to you about this if you make such a request. 

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at ROE_DPO@tencent.com

Erasure

If there is any personal information you believe we process that you would like us to erase, please contact us at ROE_DPO@tencent.com.

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 this Game and there are grounds for erasure, we will use reasonable steps to try to tell others who are displaying the personal information or providing links to the personal information to erase it too.  

Restriction of Processing to Storage Only

You have a right to require us to 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). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at ROE_DPO@tencent.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at ROE_DPO@tencent.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.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend Game access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature. 

Contact & Complaints

We welcome questions, comments and requests regarding this privacy policy. Please address them to ROE_DPO@tencent.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at ROE_DPO@tencent.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you consider we have infringed data protection laws.

Changes

If we make any material changes to this privacy policy, we will post the updated privacy policy in-game and on our website (https://www.ringofelysiumonline.com/). Please check frequently to see if there are any updates or changes to this privacy policy.


SUPPLEMENTAL TERMS FOR USERS LOCATED IN BRAZIL, CANADA, JAPAN, THE REPUBLIC OF KOREA, AND RUSSIA

Some countries’ laws contain additional terms for users of this Game, which are set out in this section.

If you are a user located in Brazil, Canada, Japan, the Republic of Korea, or Russia, the terms set out below under the name of your country apply to you.

Brazil

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL DATA, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

Canada

Service providers

 

If a user located in the province of Alberta, Canada, wishes to obtain written information about our policies and practices with respect to service providers, they may contact us at ROE_DPO@tencent.com.  Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

Japan

Your Rights

 

You may request us to notify purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at ROE_DPO@tencent.com.

Republic of Korea

How We Store and Share Your Personal Information

Delegation of Processing

For the performance of the services detailed in this privacy policy, we delegate the processing of your personal information to the following professional service providers:

Delegatee

Descriptions of Delegated Services

Tencent America LLC

Internal data and infrastructure services.

Oriental Power Holdings Limited

Aceville Pte Limited

 

Your Rights

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Act on Promotion of Utilization of Information and Communications Network (the “Network Act”).

You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the Network Act.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Network Act.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

·       Data Protection Officer, responsible for the management and safety of your personal information

·       +86 0755 8376 5566

·       ROE_DPO@tencent.com

Russia

If you are using this Game in Russia, you consent (for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations) to the processing in accordance with this privacy policy of your information. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Hong Kong, the United States, Singapore, Germany and the People’s Republic of China (excluding Hong Kong, Taiwan and Macau).