Privacy Policy

Last Updated : {May 11. 2022}

1. Who is Processing your personal data?

We at “Kakao Games” Europe B.V., a Dutch company registered with the Dutch Trade register under no. 62780476, having its registered office at Handelsweg 59J 4th Floor, 1181 ZA Amstelveen, The Netherlands (hereinafter, “Kakao Games” or “we”), take the protection of your personal data seriously. That is why we ensure that your personal data is secured and monitored against abusive use and access by unauthorized parties.

This document (hereinafter: “the Privacy Policy”) is intended to provide you (hereinafter “you” or “the user”) with simple and accurate information about the personal data we collect, how we collect and process the personal data and for what purposes. Your rights with regard to the collected personal data are also mentioned in this Privacy Policy.

Before using our services please read this Privacy Policy carefully.

For the processing activities described in this privacy policy, we qualify as a joint data controller under the General Data Protection Regulation (GDPR), together with Kakao Games Corporation, established in South-Korea. You may treat Kakao Games Europe B.V. as your main point of contact with respect to any questions, concerns or exercising of your rights with respect to the processing of your personal data in the context of the processing activities described in this policy.

We reserve the right to make changes to this Privacy Policy at any time. In such an event, we will notify you either with an official announcement on our website http://elyon.playkakaogames.com (hereinafter: “the Website”) or with an email sent to your registered email address. Announced changes will only come into effect after a reasonable period of time. You can reject the updated Privacy Policy by stopping the use of our Website.

2. Data Protection Officer contact details:

You may contact our data protection officer for any questions about the processing of your personal data as described in this Privacy Policy, and to exercise your data subject’s rights by using the contact details below:

by email at privacy@playkakaogames.com

3. What does “personal data” mean?

Personal data means "any information relating to an identified or identifiable natural person” (Article 4 (1) of the General Data Protection Regulation (hereinafter: “GDPR”)).

4. What personal data do we gather about you when you visit the Website or register with “Kakao Games”?

We collect personal data in order to improve your experience at our Website, to deliver the Website to you, for purposes of account registration, to enter into agreements with you, to provide you with requested information like newsletters, (email) updates and other information about our games and products. We also collect personal data to secure our Website, and where necessary, to determine, exercise or defend our legal position and rights.

We also process data that you leave on our Website, like your contact details, online behavior, information about your internet or Website traffic.

5. How do we process personal data?

We collect and process personal data to provide the following services and based on the following legal grounds:

To execute the agreement with you:
  • For registration and identification of members on the “Kakao Games” membership platform.
  • To deliver the services of “Kakao Games” to the users.
  • For the processing of purchases of the game and purchases available on the Website.
  • For notifying users of major changes regarding “Kakao Games” membership platform and game services.
  • For game service processes.
  • For customer service processes.
  • For reward processes and disclosure of rankings of game contests and events.

In order to enter into the agreement with you we shall collect your (user)name, email address, account data and in case of paid services, your payment details. Without such data we are unable to complete your registration or deliver the game or purchased virtual goods to you.

For the purposes of our legitimate business interests:
  • For legal obligations and litigation handling, to determine, defend or exercise our legal position and rights.
  • For analytical and statistical purposes, to improve, maintain and secure our Website and Games.
  • To respond to your requests, complaints and communications, to verify your identity, to process your transactions, to provide technical support and troubleshooting, and for other customer service purposes.
  • To develop new products and services.
  • For member identification, fraud prevention, and detection of improper usage.
  • For notification of activities to friends, user search & sign-up.
  • To tailor the content and information that we may send or display to you, to offer personalized content and to assist us in advertising our services.
  • To send you event information, marketing messages and advertisements.
  • Targeting advertisements using external media.
  • To better understand how the users access and use our Website, to respond to user desires and preferences, and for other research and analytical purposes;
To comply with our legal obligations:
  • Where required by law or legal process
  • To comply with a binding request.
Based on your consent:
  • For email newsletter distribution
  • For functional cookie processes on the main website.

The processing of personal data for the above purposes is performed with consent when members register and access the website and can be changed through the My Information page. You can at any time withdraw your consent thereto at any time via the unsubscribe button in the newsletter, by contacting us or by changing your settings (as indicated above).

6. Will Kakao Games Europe share my personal data?

Kakao Games” may share your personal data with the following categories of recipients:

Other Users.

To other users/friends if you choose to share such information.

Service Providers.

Third-party vendors, service providers, payment service providers, contractors or agents that perform functions on our behalf may be outside the United States or the EU.

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.

In order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

To Protect Us and Others.

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 use as may be applicable to a specific game or purchase or this Privacy Policy, or as evidence in litigation in which “Kakao Games” is involved.

We may share and disclose aggregate or de-identified information about users of our Website with third parties for marketing, advertising, research, analytical or similar purposes.

To our joint data controller, Kakao Games Corporation.

To be able to operate the “Kakao Games” membership platform, to provide you with the Kakao Games services and to enable Kakao Games Corporation to comply with applicable laws.

With your consent, for any other purposes.

7. International Data Transfer

Information we collect may be transferred or disclosed to recipients located in countries outside your home country for the purposes set out in this Privacy Policy.

You understand that these countries, including South-Korea and the United States, may not provide the same level of data privacy protection as the European Union/European Economic Area or your home country. We shall take adequate measures to ensure that this always takes place in accordance with the relevant legislative requirements in this respect. You may contact our Data Protection Officer to gain further information on these measures.

8. Data retention

We retain your data for as long as your account is active or as needed to provide you with a requested service or handle a request or complaint. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data.

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. How do we protect your personal data?

In order to help ensure a secure and safe user experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

10. Information received from other platforms

We receive your personal data from third parties when you login on our platform using external accounts of these parties (Steam, Facebook, Google, etc.). The personal data we receive from these parties are processed by us to be able to grant you access to our platform. To the extent required by applicable laws, we will first obtain your prior consent for the use of your personal data for these purposes. For information about the way these third parties process your personal data, we kindly refer to the relevant according to consent with you and third parties’ privacy policy which can be found on their website.

11. What are Cookies?

The Website uses "Cookies". These are small files that get saved on your computer and enable the analysis of your use of the Website. We do this to gather information about the pages on our Website users visit, to keep track of how often users come back and to see which pages are doing well on the Websit.

We also keep track of what information the browser shares. We do this online using the following tools and cookie:

Functional Cookis

We use functional cookies. The functional cookies we use are session ID cookies. These cookies are necessary for the proper functioning of the Website. For example, we use cookies to log in and respond. The functional cookies allow us to keep your account session open while you browse. This means that you do not have to log in at every page agai.

Your consent is not required for such cookies. Please note that session ID cookies are required for the proper functioning of our website. The data collected and processed by these functional cookies are your IP address, browser information, date and tim.

The collected and processed (personal) data by the session ID cookie expires after the end of the browser session if you have not checked the "Stay logged in" box when you signed up on our Website. If you checked the box 'stay logged in' the cookies expire after 24 months. These third-party cookies follow individual behavior on our Website. It creates profiles, for example to enable targeted advertisements. The tracking cookies also collect data relating to the traffic to the Website. We use this information to determine how our site is found and used to ultimately improve your experience on our Websit.

Facebook Pixl

We also use Facebook Pixel. Facebook Pixel is a tracking code cookie provided by Facebook. It allows us to track which advert brought you to our Website and which pages you visited on it. It helps us to make our advertisement campaigns more efficient. We act as joint controllers together with Facebook for the collection and processing of your personal data and the transfer thereof to Facebook as described here https://www.facebook.com/about/privacy. We note that you have the right to contact both Facebook and “Kakao Games” for any questions or requests relating to the processing of your personal data in this context, or to exercise your rights. If you contact “Kakao Games”, your request and relevant information shall also be transferred to Facebook. For more information and the Terms and conditions as agreed upon by us and Facebook in this respect we refer to: https://www.facebook.com/legal/controller_addendum.

12. What are my rights?

Under certain circumstances, you have the following rights:

Right to be informed

To ensure fair and transparent handling of personal information, “Kakao Games” must inform its users on how their personal information is being used. If the user requests information on how his or her personal information is being used, “Kakao Games” must provide the relevant information in a simple and straightforward manner. Users may make these requests through Customer Service or by contacting the Data Protection Officer.

The right of access

You have the right to obtain confirmation from us as to whether personal data concerning you has been processed by us. You also have the right to access the personal data and information about (inter alia): the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipients to whom the data have been or will be disclosed.

The right to rectification

You have the right to obtain the rectification if the personal data that we have processed from you is incorrect or inaccurate. We will correct your personal data without undue delay.

The right to erasure (the right to be forgotten)

You have the right to obtain the deletion of your personal data if one of the reasons stated in article 17 GDPR applies.

The right to restriction of processing

You have the right to obtain verification from us if one of the reasons mentioned in article 18 GDPR applies.

The right to data portability

You have the right to receive the personal data that concerns you that you have provided to us. You receive the data in a structured, commonly used and machine-readable format. You also have the right to ask us to transmit this data to another controller.

The right to object

You have the right to object to the data processing if the data processing takes place on the grounds referred to Article 6 (1) (e) or (f) GDPR. We will no longer process the personal data unless we are able to demonstrate convincing legitimate interests for the processing that exceed your interests, rights and freedom or when this is necessary for instituting, exercising or defending legal claims.

The right to lodge complaints with the Data Protection Authority

You have the right to lodge a complaint about the processing of your personal data with the competent data protection authority in your country.

Right related to automated decision making and profiling

In the case of when an issue may have major repercussions such as issues which require legal action, the user will not be affected by decisions which are based on automated systems such as profiling. In these cases, the user may request a withdrawal of such decisions.

If you have questions about this Privacy Policy or your rights, please contact us. You can reach us at the following e-mail address: privacy@playkakaogames.com


Appendix - How to remove cookies:

Internet Explorer:

Launch Internet Explorer; at the top-right open the Internet Options Menu; on the General tab, select Delete, in the Browsing History Section; select the Cookies check-box, and click the Delete Button.

Chrome:

Open Chrome; at the top-right, click Settings; at the bottom click “Advanced”; in the 'Privacy and security' section, click Content settings; under “Cookies”, click “All cookies and site data”; at the top-right, click “Remove all”; at the bottom-right, click “Done”.

Opera:

Go to 'Settings'; Select “Preferences; Select “Advanced”; select “Cookies”; click on 'All cookies and site data'; there you can click on 'Delete all'.

Firefox:

Click the menu button and choose Options; Select “Privacy and Security”; under History, set Firefox will: to Use custom settings for history; click “Show Cookies”, the Cookies window will appear; In the Search: field, type the name of the site whose cookies you want to remove. The cookies that match your search will be displayed; select the cookie(s) in the list to remove and click Remove Selected.

Safari:

On the Safari Menu, click on 'Preferences'; select 'Privacy'; set your preferences for accepting cookies next to 'Block Cookies'; select 'Parties and Advertisers' - 'Always' or 'Never'; if there are any website data/cookies being stored, click 'Details’; to remove specific data, highlight the information and click 'Remove'; to remove the data from all the sites, click 'Remove All'.