​THUMB AGE Inc. respects the privacy rights of its customers and protects the personal information collected, stored and used in connection with THUMB AGE products, services and websites (the "Services"). 

To further this commitment, we have adopted this Privacy Policy ("Policy") to guide how we collect, store, and use the information you provide us.

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy describes THUMB AGE's collection and use of your personal information submitted and collected through the Services. The term "Personal Information" as used in this Privacy Policy includes any individually identifiable information about the user, including but not limited to name, address, telephone number, e-mail address or any other identifier of a user, and information concerning that user collected and/or maintained in personally identifiable form.

BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE SERVICES, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.
IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES.

2. THE INFORMATION WE COLLECT

We may collect different information from you when you use our Services. The following are examples to help you better understand the types of information that we collect.

Information we collect

When you use our Services, we may collect and store information from you directly. For example, when you register with us, we may collect certain information from you, including your name, email address, username, nicknames, passwords, social networking usernames, and information. Once registered, you may also have the option of completing a user profile.
Your user profile may include Personal and Non-Personal Information, depending on how you complete the profile. When you contact us, we also collect certain Personal Information in order to be able to respond to you.

Contacts

We offer you the ability to locate, invite, and play games with your contacts. To do so, THUMB AGE may request access to your address book or social networking accounts.
We will ask you for your permission before we access and store your contacts.

Device Information

When you use our Services on your mobile devices we may collect information regarding your devices, including your unique device identifiers and Internet Protocol (IP) address.
We may also collect the name you have designated for your device, the device type, and the country code from which you connect. We do not track your precise location.

Technical and Usage Information

When you use our Services, we collect technical and usage information such as your browser type, browser language, referring and exit URLs, platform type, interactions with other users, and usage statistic with the Services. 

For more information on how we utilize log files and cookies, please refer to the Article 3 below.

3. HOW WE COLLECT INFORMATION ABOUT YOU

Information You Provide Directly

When you use our Services, we may collect information that you provide us directly, including without limitation:

• Registration and Profile Information: Your username and other related information for purposes of registration or creating a profile;

• Payment Information: Billing information for completing transactions;

• Publicly Shared Information: Information that you share publicly via our Services, such as postings in community forums, message boards and blogs, chat in public channels, and your public profile. 

  You are accepting that such public information may be collected, and we shall not be liable in any way for collection and/or disclosure of such information;

• Information for Customer Support: Information that you provide when you contact us for assistance or to report a problem;

• Friends List: Your friends list (e.g. if you refer others to our Services or form a group within our Services);

• Sweepstakes/Promotions: Information that you provide in order to participate in sweepstakes and promotions.

Setting up and Deleting Information Collected through Technology

We collect information through technology to make our Services more useful and interesting to our users, including without limitation:

• Cookies

We may use cookies to track general, non-personal Information about our users for statistical and market research purposes (e.g., user name, pages viewed, time spent on applications, websites visited just before and just after our Services, etc.). 

This information is collected on an aggregated and anonymous basis. Log Files. Like most Internet services, we may also use log files on the server side. 

The data held in log files includes your Internet Protocol (IP) address, browser type, Internet service provider, referring/exit websites, device type, date/time stamp, and user activity (e.g., feature usage, user rankings, game statistics);
The user has the right to select regarding installing cookies. The user can decide in the device settings whether to allow cookies, and also delete them. 

However, when not allowing use of cookies, there can be problems when using services required for login.

[Cookie setting and deleting method]

- Microsoft Edge: At the top of the web browser, [ ] → [Settings] → [Cookies and site permissions]
- Internet Explorer: At the top of the web browser, [Tools] → [Internet Options] → [Personal Information] → [Advanced]
- Chrome: At the top right of the web browser, [⋮] → [Settings] → [Personal Information and Security] → [Cookie and other site data]

• Temporary Files

In addition, the software enabling our websites may have associated log and temporary files that are stored on our servers. 

These files store your account information, preference settings, system notifications as well as other data necessary to enable you to use our Services. 

Your information may also exist within regularly performed server backups. This information is collected on an aggregated and anonymous basis;

• Patches

When any game or application is updated or "patched," our patch routine may check your device to see that you have the most recent version of the files;

On an aggregated and anonymous basis, we may also collect other information through technology, such as information on our users' hardware, operating systems, and usage patterns.

Information Received Through Your Third Party Platform Account and Mobile Device

When you use or connect to our Services on or through a third party platform, such as a social networking site (including using a third party platform account to sign into our Services), you allow us to access and/or collect certain information from your third party platform profile/account as permitted by the terms of the agreement and your privacy settings with the third party platform. 

The information you allow us to access and collect varies, depending on the Service you use, the terms of the third party platform and your privacy setting there. 

You may be able to disallow the third party platform from providing us with certain information about you by changing your privacy settings there.

If you use our Services via a mobile device, we may, in accordance with the terms of any applicable agreement with the mobile device carrier (and as allowed by your privacy settings) collect certain information such as your unique device identifier (a number automatically assigned to your mobile or wireless device), device type, and information you choose to provide or share, such as e-mail address.

4. USE OF THE INFORMATION COLLECTED

We may use the information we collect for a variety of purposes, primarily for operating and improving our Services. Our uses include without limitation:

• Communications: Communications with you about your account and our Services, such as new features and offerings;

• Services: Providing our Services, such as fulfilling requests and resolving customer support issues;

Analysis: Analyzing trends and user behavior to improve our Services and develop new Services;

• Protection: Protecting our Services from misuse and, as may be necessary or appropriate in our determination, to protect the safety and security of our users, employees and third parties, or the integrity of our Services. Among other forms of communications, we may send push notifications to your mobile device to provide game updates and other relevant messages. You can manage push notifications from the "options" or "settings" page within the mobile application. You also may be able to manage them from your device's settings page.

Finally, we may take your Personal Information and make it non-personally identifiable. We do this either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (e.g., your name) that make the information personally identifiable to you. This process is known as de-personalizing your information. Given the non-personal nature of this information, no restrictions apply under this Privacy Policy on our right to use de-personalized information.

Illegal Activities: We reserve the right to release and/or use all information contained within our databases, access logs or other records concerning you if you violate our Terms of Use, End User License Agreement or other rules, policies, notices, agreements or guidelines, or intentionally or unintentionally partake (or are reasonably suspected of partaking) in any illegal activity, including, but not limited to, hacking, even without a subpoena, warrant or other court order, and to release such information in response to court and governmental orders, civil subpoenas, discovery requests and as otherwise required by law, and/or to initiate our own legal proceedings. We cooperate with law enforcement agencies in identifying those who may be using the Service (or any part thereof) for illegal activities. We also reserve the right to report any suspicious or suspected illegal activity to law enforcement individuals or entities for investigation or prosecution.

5. PERIOD OF RETENTION OF COLLECTED PERSONAL INFORMATION

In principle, if the collection and use purpose of personal information is achieved, the information is destroyed without delay. However, to resolve consumer complaints and disputes when withdrawing from the game, and to resolve unwanted withdrawals, etc. from illegal use of personal information, the personal information is retained for 15 days after withdrawal is requested.

Also, if there is a need to preserve the information after the collection and use purpose is achieved due to relevant legislation, the company stores the user’s information for a designated period of time determined by relevant regulations as follows.

Retaining information due to company interior policies

1) Selecting event and promotion winners
- Information collected for events and promotions: 6 Months
* However, the duration can differ depending on the events and promotions, and the period posted on individual events and promotion pages are applied with priority.

Retaining information due to relevant legislation

1) Act on the Consumer Protection in Electronic Commerce, Etc.
- Records related to labeling/advertisement: 6 Months
- Records related to agreements or subscription withdrawal: 5 Years
- Records related to payments, supply of commodities: 5 Years
- Records related to consumer’s complaints or settlement of disputes: 3 Years
2) Protection of Communications Secrets Act
- Records on website visit: 3 Months
3) Framework Act on National Taxes
- Books and evidential documents related to all transactions as defined by tax law: 5 Years

6. PROCEDURE AND METHOD OF DESTRUCTION OF PERSONAL INFORMATION

In principle, after the collection and use purpose of personal information is achieved, the information is destroyed without delay. The disposal procedure and method are as follows.

Disposal Procedure

For information entered by the user for user registration, service signup, etc., after the collection and use purpose of personal information is achieved, based on interior policies and information protection reasons in accordance with legislation (refer to ‘Article 5. PERIOD OF RETENTION OF COLLECTED PERSONAL INFORMATION’), it is retained for a certain period of time before being disposed.

Disposal Method

1) Personal information preserved in electronic file formats is to be deleted using technical means which makes the information irrecoverable.
2) Personal information printed on paper is to be destroyed through shredding or incineration.

7. SHARING OF YOUR INFORMATION

We will not share your Personal Information with unrelated third party advertisers.

We will only share your Personal Information with third parties under the following circumstances:

• Our Service Providers: We may utilize or partner with other companies to provide our Services, such as vendors and service providers that analyze customers' interaction with our Services, and handle consumer surveys, or companies that co-develop or co-publish games with us. While providing their services, these companies may access your Personal Information, but we will direct them to maintain the confidentiality of such information and use it solely for performing the applicable services;

• Required Disclosures: We will disclose Personal Information when we believe in good faith that disclosure is required or permitted by law (e.g., court order or subpoena) or such disclosure helps (i) enforce our terms of use, contests, sweepstakes, promotions, game rules, or similar restrictions, or (ii) protect the safety and security of our users, employees and third parties, or the integrity of our Services;

• Mergers and Corporate Transactions: In the event that we undergo a business transition, such as a merger, acquisition, joint venture, corporate divestiture or dissolution, a sale of assets, or similar transactions, we may share, disclose or transfer your information, including Personal Information, to the other organizations that are parties to such transactions.

• Sweepstakes and Promotions: We may share your information in connection with any sweepstakes or promotions you enter in connection with our Services, as necessary to administer, market, sponsor, administer or fulfill them or as required by applicable laws, rules or regulations;

• Miscellaneous: Our Services may display "offers" that are hosted by third party providers. The offers may, for example, provide virtual currency to users in exchange for interacting with an advertisement or for completing a marketing offer. To properly credit user accounts and to prevent fraud, a unique identifier, in some cases your user ID, may be shared with the offer providers. Please be aware that, after clicking on one of these offers, you will no longer be on our Services, and information that you provide will go directly to the third party provider With Your Permission. Additionally, if you opt-in or otherwise agree to have your information shared with a third party (or third parties), we will share your information accordingly, in which case the third party's use of your information is subject to the third party's own privacy policy.

As discussed above, we may use de-personalized information in any way, including sharing it with third parties, without your consent. Among other things, we may share some of the information we collect from you upon installing a mobile application with vendors and other service providers who are working with us in connection with the operation of Our Services and/or for analytics purposes which may require the reproduction and display of de-personalized information. You may be able to "opt out" of the collection of your information for third party analytics purposes by following the directions provided by our third party analytics vendor. If you "opt out" with one third party analytics provider, that action is specific to that provider only and does not otherwise limit our information collection under the terms of this Privacy Policy.

Partners and service providers

- Company: Vergeos
- Consigned Duties: Customer center consultation (email, phone), provide event items, operate SNS
- Address: #503, Seonghwan Bldg, 14, Gangnam-daero 152-gil, Gangnam-gu, Seoul, Republic of Korea
- Contact: biz@vergeos.co.kr
- Country: Korea

8. COLLECTION AND USE OF CHILDREN'S PERSONAL INFORMATION

Our Services are not intended for children under the age of 15, and we do not knowingly collect any Personal Information from anyone under the age of 15. If you are under 15, please do not send us any information about yourself and you should not use or attempt to use our Services.

Further, in the event we discover that we have collected Personal Information from children under age 15, we will promptly delete such information in a secure manner.
If you believe that we might have any information from or about children under age 15, please contact us at our Customer Support Center through in-game setting or option menu.

Please note that all persons under the age of majority in their jurisdiction are required to have a parent or guardian read and accept this Privacy Policy and the Terms of Use on their behalf. Parents are encouraged to supervise their children's use of our Services and to become familiar with the types of content available through our Services.
Parents should oversee their children's use of e-mail, forum and other online communications.

9. SECURITY OF YOUR INFORMATION

We are committed to safeguard your information, and we implement reasonable security measures to protect the security of your information.
We also constantly update our technology with the goal of better protecting your information.

While we take reasonable precautions against possible security breaches, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will not occur. We urge you to take steps to keep your Personal Information safe, to use strong passwords, to log out of your account after use, and to use different passwords for different services with different companies. It is important that you also help protect and maintain the security of your account. Please notify us immediately of any unauthorized use.

10. CALIFORNIA CONSUMER PRIVACY ACT

The company abides by the California Consumer Privacy Act

Personal information collected/shared for duty purposes

The company can collect/share the following categories of information that can directly/indirectly identify the user or their device, or information that can be reasonably connected to the user or their device ("personal information") for business purposes.

Identifiers: Nickname, unique identifier, online ID, IP, email address, account name or other similar ID
Commercial information: purchased/obtained/collected item or service, other records on purchase, consumption history or tendency
Geolocation data: Geographic location data such as country of residence

Purpose of collection

The personal information above is used/shared for purposes such as enhancing service quality, providing service, maintaining account, customer response service, customer confirmation, advertisement, and user pattern analysis as follows.

Resolving technical issues and enhancing quality of company service 
Individual user identification to provide company service  
Technical protection against use of unauthorized programs related to the company service
Preventing inappropriate gameplay that can negatively affect other users of the company service
Providing customer support on the company service through customer inquiry collection and response
Provide game related service on the company website
Provide information on company events and surveys, provide opportunities to participate in company events and surveys, provide company advertisement and use for other company marketing and promotional purposes
Track usage pattern, user trend analysis, calculate company service use statistics

Ban of personal information sale

The company does not “sell” the information of customers that use the company’s service for monetary benefit or specific benefits for the company.

Ban discrimination

While some features of the service provided by the company can be saved or no longer provided, the company does not discriminate users that exercise their rights in accordance with CCPA.

California Consumer Protection Act

1) California residents have the right to receive explanations on the identification information of company or duty consignment company that has utilized their personal information for marketing purposes, and the category of utilized personal information.
After receiving information reveal request that fits the requirements, the company provides the following information.
- Personal information items of the requester collected by the company over the last 12 months.
- Category of sources from which the personal information was collected over the last 12 months.
- Personal information items that the company shares with duty consignment company.
- The company’s business/commercial purpose of collecting and sharing the select personal information
- Specific user personal information that the company collected over the last 12 months.
- If the user’s personal information was disclosed for business purposes, explanation on what categories of personal information were collected and used by the recipient through what means
2) If the user is a California resident, the user has the right to request deleting the personal information collected and owned by the user in accordance with a specific exception. After the company receives and confirms the user’s request, if it is not an exception in accordance with CCPA, the user’s personal information is deleted.

11. LAWFUL PROCESSING OF PERSONAL INFORMATION UNDER GDPR

Processing personal information by the Company shall be lawful only if and to the extent that at least one of the following applies.

A user has given consent to the processing of his or her personal information.

• Processing is necessary for the performance of a contract to which a user is party or in order to take steps at the request of a user prior to entering into a contract:
- Member management, identification, etc.
- Performance of a contract in relation to providing the services required by users, payment and settlement of fees, etc.
• Processing is necessary for compliance with a legal obligation to which the Company is subject
- Compliance with relevant law, regulations, legal proceedings, requests by the government
• Processing is necessary in order to protect the vital interests of users, or other natural persons
- Detection of, prevention of, and response to fraud, abuse, security risks, and technical issues that may harm users or other natural persons
• Processing is necessary for the performance of a task carried out in the public interest or in the excise of official authority vested in the Company
• Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child).

User’s right when applying GDPR

The users or their legal representatives, as main agents of the information, may exercise the rights regarding the collection, use and sharing of personal information by the Company.
Details can be found in ‘Article 8. COLLECTION AND USE OF CHILDREN'S PERSONAL INFORMATION’, and for requests for rights, please contact to 'Article 13. DATA PROTECTION OFFICER’.

12. RIGHTS AND EXERCISE METHOD OF USER AND LEGAL GUARDIAN

The user and legal guardian can exercise their rights to view, correct, delete, or request suspension of personal information at any time.

[How to withdraw consent to provide personal information]

1) To delete the personal information (Consent withdrawal), click "game withdrawal" in the service to proceed with the deletion.

  However, if the personal information of the user is disposed from the withdrawal, the relevant information that has been created/accumulated while the user used the company’s service can also be deleted.

2) In the event that you wish to make a complaint about how we process your personal data, please contact the data protection officer in writing or email (dekarong_help@thumbage.co.kr) and we will endeavor to handle your request as soon as possible.

  However, the company can reject opening or modifying some or part of the user’s personal information if there is justifiable cause, and at this time notify the rejection of the user and justify it with reasoning.

3) A request for correction and deletion of personal information cannot be requested if the personal information is specified as the subject of collection in other laws.

When the user has requested correction of personal information error, the select personal information is not used or provided until the correction is complete. 

Also, if incorrect information has already been provided to a third party, the correction processing is notified to the third party without delay.

Personal information disabled or deleted by the company upon the user or legal representative’s request is processed in accordance with ‘Article 5. PERIOD OF RETENTION OF COLLECTED PERSONAL INFORMATION’ and it cannot be opened or used for any other purposes.

Users have the right to lodge a complaint with the supervisory authority, in particular in the EU Member State of users habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to user.

13. DATA PROTECTION OFFICER

The company is designating a data protection officer as follows to protect the customer’s personal information and process relevant complaints.

Data Protection Management Team
- Team: DekaronG
- Contact: dekarong_help@thumbage.co.kr

14. LEGAL MATTERS

If any court or other competent authority finds any of the terms of this Privacy Policy to be invalid or unenforceable, the other terms of this Privacy Policy will not be affected.

This Privacy Policy is governed by and interpreted in accordance with the laws of Republic of Korea. Any dispute arising in connection with this Privacy Policy will be subject to the exclusive jurisdiction of the courts of Republic of Korea unless you choose the courts of your home country.

We are constantly innovating and looking for new ways to improve our Services and our Website. We may therefore amend this Privacy Policy from time to time to reflect such improvements or any other changes to our business. We will endeavor to tell you about any significant changes to this Privacy Policy which we feel may disadvantage you in any material way. If you object to any of the changes you should immediately stop using our Services and close any account, you may have with us.

15. QUESTIONS OR COMMENTS

If you have any questions, comments or concerns regarding our Privacy Policy or practices, please contact us at our Customer Support Center through in-game setting or option menu.

Last updated: 12, Sep, 2023