Ring of Elysium Privacy Policy

Last Updated:  November 20th, 2018

SUMMARY

What information do we collect about you?

We collect information when you set up your account for the Game, when you use the Game, when you make in-Game purchases and when you contact our support team. More Information.

How will we use the information about you?

We use your information to provide the Game to you. We use your information to allow you to manage your account and to support and improve the Game. More Information.

Who do we share your information with?

We use third parties for the provision of cloud services. We use these third parties services solely to process or store your information for the purposes described in this policy. We also share your information with our related group companies and as required by law. More Information.

Where do we process your information?

Our servers are located in Hong Kong, the United States and the People’s Republic of China (excluding Taiwan, Hong Kong and Macau). 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). More Information.

How long do we keep hold of your information?

We generally retain your information for the Game for the period during which you maintain an account. We delete certain information earlier at your request, and in accordance with local law. More Information.

How can I exercise my rights over my information?

You may have rights to access, receive copy of, or delete, your data or restrict or object to our processing of, your data. More Information.

Dispute Resolution

If you have any concerns or complaints, please contact us here.

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will notify you within the Game. More Information.

Contact Information

Data Controller: TCH Scarlet Limited Email: ROE_DPO@tencent.com

EU Representative: Tencent International Service Europe B.V. Email: eudataprotection@tencent.com

 

INTRODUCTION

This privacy policy informs you of your choices and our practices regarding any personal information you provide to us. Your use of the game Ring of Elysium (“Game”) involves the collection and use of your personal information. It is important for you to understand how this happens and how you may control it.

When you contract to use the Game, you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using, providing to third parties, and storing your personal information, as described in this policy.

 

You acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy, you must not use the Game. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.

 

Our company name is TCH Scarlet Limited, an lrish company, and our registered address is Harcourt Center, Block 3, Harcourt Road, Dublin 2, Ireland. Our representative in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V., a company registered in the Netherlands. Their registered address is 26.04 on the 26th floor of Amstelplein 54, 1096 BC Amsterdam, the Netherlands and they can be contacted at eudataprotection@tencent.com. Our data protection officer can be contacted at ROE_DPO@tencent.com. The data controller for the purpose of EU data protection laws is TCH Scarlet Limited.

If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at: ROE_DPO@tencent.com.

The Types of Personal Information We Use

This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:

·         Information you provide when registering for the Game. The Game is hosted on the Steam platform operated by Valve Corporation (hereafter referred to as “Steam”). When you register for the Game, we receive from them your Steam ID.

 

·         Information we collect about you. We automatically collect certain data from you when you use the Game, including your account ID (a unique number given by us to users), IP address and device information associated with your advertising ID (CPU, memory, operating system and graphics card). We also collect and store your data as follows:

·         if you conduct any transactions within the Game, we receive information to facilitate your transaction and store your information to maintain transaction records (your Steam ID, country/region code, currency code, in-game language code, order ID, IP address, price and item information);

·         when you are using the Game our security feature collects user basic hardware information (manufacturer, model number, serial number information, input devices and displays), operating system information, machine codes for security authentication, user account information, network information, network filters, handle information, information about installed anti-virus software, information related to script (plug-in) in browser, process files and memory data during Game play, driver information loaded during Game play, dump file that records crash details when a crash occurs, virus interception information in anti-virus software, installed script (plug-in) data, running script (plug-in) data, data of computer process which may used by script (plug-in), user behaviour and status that may be related to plug-in use, , event tracing, known files related to cheat tools, debug tools, virtual machine tools, paths, hashes and hooks in use when the Game is running, image files, memory image, shellcode loaded by the Game, system API calls, method calls, system procedures and related data of active windows, information on in-game modules, game screenshots and server configuration of ShadowSocks;

·         if you contact our support team, we collect the same information that is collected by our security feature.

 

·         Information you generate and display in the course of using the Game. We collect information that you generate in the course of using the Game. The Game data that we collect includes your virtual character, its fashion and game play statistics (level, heroes and score/s). The Game log information that we collect includes account ID, character ID, nickname, server, channel, records when you log in and log out of your account, and your access to the Game room.

Children

The Game is not intended for or targeted toward users under the age of 13 years old; or in the case of users located in a country listed in the table below, the relevant age listed for that country.

 

Country in which the user is located

Minimum age of the user

Brazil

18

European Economic Area

16

Japan

16

Republic of Korea

14

Russia

14

Switzerland

16

 

 

We do not knowingly collect personal information from children under this age 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

We will use the information in the following ways and in accordance with the following legal bases:

Personal Information

Use

Legal Basis for Processing (EU)

Game

Steam ID

We receive your Steam ID from Steam on the creation of your account for the Game.

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

Account ID, IP Address, Advertising ID (CPU, memory, operating system, graphics card)

We use your account ID and your IP Address to improve our services and operational support.

We use your device information associated with the Advertising ID to improve our services, including the functionality of the Game on different devices.

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

Game Data: virtual character, its fashion, game play statistics (level, heroes, score/s)

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

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

Game Log Information (records of log in and log out, 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 the Game; and

·         for troubleshooting purposes.

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

In-Game Purchase 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 the Game and to restore purchases of in-game items.

Security-Related Information: Basic hardware information (manufacturer, model number, serial number information, input devices and displays), operating system information, machine codes for security authentication, user account information, network information, network filters, handle information, information about installed anti-virus software, information related to script (plug-in) in browser, process files and memory data during Game play, driver information loaded during Game play, dump file that records crash details when a crash occurs, virus interception information in anti-virus software, installed script (plug-in) data, running script (plug-in) data, data of computer process which may used by script (plug-in), user behaviour and status that may be related to plug-in use, event tracing, known files related to cheat tools, debug tools, virtual machine tools, paths, hashes and hooks in use when the Game is running, image files, memory image, shellcode loaded by the Game, system API calls, method calls, system procedures and related data of active windows, information on in-game modules, game screenshots and server configuration of ShadowSocks.

We use this information:

·         for security purposes, including to detect cheating behaviours;

·         to provide a fair Game environment; and

·         to solve game crash and improve our services.

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

Chat Log Data

We facilitate the posting of your communications with other users.

Necessary to perform our contract with you to provide the Game where you seek to use chat services.

Customer Support Ticket ID & User Communications with Support: Information provided by you when contacting our customer support team using the relevant support email.    

 

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 the Game.

How We Store and Share Your Personal Information

In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers. Our servers are located in:

·         the United States;

·         Hong Kong;

·         the Peoples Republic of China (excluding Taiwan, Hong Kong and Macau).

We share your personal information with selected third parties in and outside your country, including:

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

·         related group companies with whom we share your personal information to operate the Game. All related group companies may only use your personal information in accordance with this privacy policy.

o   comply with a legal obligation, process or request;

o   enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof;

o   detect, prevent or otherwise address security, fraud or technical issues;

o   protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection);

Any third party (selected by us) with whom we share user data will provide the same or equal protection of user data as stated in the this policy.

The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organisational controls and our policies and procedures (including this Privacy Policy).

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; any transmission of your information is at your own risk.

Data Retention

We will retain your personal information as described below (except if otherwise required to be retained by applicable law).

Personal Information

Retention Policy

Game

Steam ID

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.

IP Address, Advertising ID (CPU, memory, operating system, graphics card)

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.

Game Data: virtual character, fashion, game play statistics (Level, Heroes, Score/s)

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.

Game Log Information (records of log in and log out, access to the Game room)

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.

In-Game Purchase Information: Steam ID, country/region code, currency code, in-game language code, order ID, IP address, price and item information.

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: Basic hardware information (manufacturer, model number, serial number information, input devices and displays), operating system information, machine codes for security authentication, user account information, network information, network filters, handle information, information about installed anti-virus software, information related to script (plug-in) in browser, process files and memory data during Game play, driver information loaded during Game play, dump file that records crash details when a crash occurs, virus interception information in anti-virus software, installed script (plug-in) data, running script (plug-in) data, data of computer process which may used by script (plug-in), user behaviour and status that may be related to plug-in use, event tracing, known files related to cheat tools, debug tools, virtual machine tools, paths, hashes and hooks in use when the Game is running, image files, memory image, shellcode loaded by the Game, system API calls, method calls, system procedures and related data of active windows, information on in-game modules, game screenshots and server configuration of ShadowSocks.

Please note: All retention periods below are subject to account deletion in accordance with your request, except for the retention periods relating to confirmed malicious files. Upon a deletion request, we will delete the data within 30 days.

We retain this data for 90 days with the following exceptions:

Hardware information, cheat tool monitoring, player identification, game operations data, and troubleshooting logs: stored for 30 days.

File sample collection and memory sample collection: stored for 7 days and then automatically deleted if the same sample information does not re-appear. If it is identified as a malicious file, however, it is stored for 3 years. In the case of malicious game memory samples, these are retained as evidence for 10 years (together with the associated account-ID, date of registration and in-game user behaviour). For files confirmed to be non-malicious, these are stored for 60 days. In the case of users' file MD5 records, these are stored for 90 days.

Actions, status collection, trail collection: stored for 90 days.

In-game process information and system information: stored for 10 years and then manually deleted.

Security authentication: stored for 730 days and then automatically deleted.

Chat 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.

Customer Support Ticket ID & User Communications with Support:

 

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.

 

 

Personal Information is kept until the end of its life cycle (as set out in the retention policy above). When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws.

Your Rights

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

The sections titled “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 in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party. 

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any personal information held about you that is inaccurate. 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 and that information is inaccurate, please contact us at ROE_DPO@tencent.com.  

Erasure

You can delete your account, or remove certain personal information, by logging into your Game account. If there is any other personal information you believe we process that you would like us to erase, please contact us at ROE_DPO@tencent.com.

You may request that we erase the personal information we hold about you in the following circumstances:

·         you believe that it is no longer necessary for us to hold such personal information;

·         you believe the personal information we hold about you is being unlawfully processed by us.

You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., 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 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 (e.g., 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.  

You may request we stop processing and just store the personal information we hold about you where:

·         you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;

·         you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead;

·         you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims. 

Objection

You have the right to object to our processing of personal information about you. 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 (such as 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

Questions, comments and requests regarding this policy are welcomed and should be addressed to: ROE@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 think we have infringed data protection laws.

Changes

If we make any material changes to this policy, we will post the updated policy here and notify our users within the Game. Please check this page frequently to see any updates or changes to this policy.


SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

If you are a user located in one the following countries, the terms set out below that apply in 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 (for Japan)

 

This section applies only to users that are located in Japan.

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 Services, 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

Shenzhen Tencent Computer Systems Company 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 you 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 the 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 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 and the People’s Republic of China (excluding Taiwan, Hong Kong and Macau).