METABORA

Privacy Policy_METABORA_EN

We are concerned about the protection of Members' personal information and are concerned with the type, scope and purpose of the collection, storage, use and processing of personal data on the website of METABORA Co., Ltd.(“Company”) and all services. We intend to provide it continuously through this privacy policy.

This Privacy Policy applies only to our services and websites and can be viewed at any time on our website. Please read this Privacy Policy carefully to check our practices regarding how we handle your personal data. If you do not agree with our policies and practices, please stop using or registering the service or visiting our website.

By visiting our website and using our products and services (including our services), you acknowledge the terms and conditions of this Privacy Policy and acknowledge that personal data may be used as set forth in this Policy.

1. Collection of Personal Information

The Company collects the minimum amount of personal information required to provide the Service.

We collect the following personal information for membership registration, customer service, and provision of various services.

email, nickname, Google Member identifier value, Game Member identifier value, profile picture, device information (model, OS information, language and country information), IP address, the version of our Services that you are using, the history that you use game and service, delinquent actions history, purchase history, Promotion/event participation record and product shipment record

2. How to collect personal information

The Company collects the information of Members in a way of the followings:

Sign up, Member’s information modification, Creating identifier value for game user, providing customer support through phone and mail, event participation, Provision based on service alliance and links, collection through generative information collection tools in the process of using or processing the service

3. Using Personal Data
Personal data is used for the following purposes to manage Members of Company’s website and related services including mobile app and mobile web, provide and improve Services:

- Member management such as identification of the user, confirmation of user’s intent to sign up and to withdraw from the services

- Performance of contracts related to the provision of services

- Providing convenience in using the service

- Handling Service inquiries and complaints
- When participating in an event held on a guild/community platform, game activity information and game member identifier value are sent to the platform

- Protection and service of Members, including restrictions on the use of service terms and conditions and related statutes, and prevention of account theft and fraudulent transactions, preservation of records for dispute settlement

- Customized service provision and service improvement according to Analysis of Service usage records and access frequency, statistics on Service use

4. Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR) and UK Data Protection Law

The Company complies with the General Data Protection Regulation (GDPR) as well as the domestic laws of each Member of the European Union, including the UK and the following may apply when the Company provides services to Members in EU countries and the UK.

[Purpose/Basis of Personal Information Processing]
The Company uses personal information collected from Members only for purposes specified in "3. Using Personal data "

The Company may process personal information in accordance with applicable laws including GDPR and UK data protection law in any of the following cases:

- Consent of the data subject

- Sign and fulfil a contract with the data subject

- Legal compliance

- For the pursuit of legitimate interests of the Company (except for cases
where the benefits, rights or freedom of the data subject is more important than that of the Company.)

[Guarantee of Members' Rights in EU Countries and the UK]

The Company is committed to protecting Members’ privacy.

In accordance with applicable laws including GDPR and UK data protection law, a Member has the rights of the data subject below.

- right to request for information about the processing of personal data

- right to request access and obtain a copy of your personal data

- right to request rectification

(When a Member requests for the correction of personal information (right to rectification),
the concerned information shall not be used or provided until such correction is completed.)

- right to request erasure ('right to be forgotten')

- right to restriction of the processing of your personal data

- right to request portability of your personal data

- right to object the processing of your personal data

The Company may also use personal information for marketing purposes such as event promotion or advertisements, for which the Company obtains a prior agreement (consent). A Member may withdraw the agreement at any time if he or she doesn't want it.

A Member may inquire the foregoing matters to the Customer Service via email (please see the section 11. How to Contact below). The request will be handled in a proper and timely manner.

Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain, for example the Ethereum blockchain, as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and NFTs held at that address.

When a Member requests for the correction of personal information (right to rectification), the concerned information shall not be used or provided until such correction is completed.

5. Provision and Entrustment of Personal Information

Personal information is provided only when a Member directly agrees to provide personal information to use the Services of an external party or if the Company is obliged to submit personal information under relevant laws, or if there is an imminent risk to the life or safety of the Member.

Data is processed only through the Company in principle, and we do not pass personal data to third parties in any case except when necessary to provide the service. When we share personal data, the categories of recipients shared are as follows:

[Service provider]

We cooperate with certain service providers (e.g. payment service providers) to provide services, and these service providers receive and process personal data based on data processing agreements concluded in accordance with our guidelines in providing those services.

[Regulatory agency]

We may disclose your personal data as follows:

- Disclosure to data protection regulators

- Disclosed for investigation by government agencies

- Disclosure to other regulatory agencies that have jurisdiction over our activities

[Metrics and trace analysis tools]

We share your personal data with Google for the use of metrics and tracking analytics tools on our services and websites.
For more information on how Google uses user data, please visit www.google.com/policies/privacy/partners/.

In addition to this, user data will only be transmitted in special exceptional cases where we are legally obligated or qualified or legally binding by public authorities.

6. Cross-Border Data Transfer

Please be aware that your personal data will be transferred to, processed, and stored in the United States, Singapore and Korea. Data protection laws in the U.S., Singapore and Korea may be different from those in your country of residence. You consent to the transfer of your information, including personal information, to the U.S., Singapore and Korea as set forth in this Privacy Policy by visiting our Sites or using our service.

The details of cross-border transfer are as follows.

recipients	Details of Work
Amazon Web Service (AWS)	Purpose: Data storage and operation for BIRDIE SHOT game services
	Items: Information used for service use which can be found in this Privacy Policy section 1. Items of Personal Information and Collection Method
	Country / Method: AWS Singapore / Transferred through the network when the service is used
	Contact: abuse@amazonaws.com
	Retention Period: Until Member withdrawal or expiration or termination of the entrustment contract or it shall be subject to the storage period prescribed by other statutes.
Onionfive Inc.	Purpose: Providing tools related to customer support service
	Items: Email, and additional personal information may be asked prior to the collection and collected to provide the service
	Country / Method : South Korea region on AWS / Transferred through the network when the service is used
	Contact: legal@support.oqupie.com
	Retention Period: Until Member withdrawal or expiration or termination of the entrustment contract or it shall be subject to the storage period prescribed by other statutes.
KnWorks Co., Ltd.	Purpose: Customer center operation and customer support service for game service
	Items: Email, and additional personal information may be asked prior to the collection and collected to provide the service
	Country / Method : South Korea region on AWS / Transferred through the network when the service is used
	Contact: heal.park@knworks.co.kr
	Retention Period: Until Member withdrawal or expiration or termination of the entrustment contract or it shall be subject to the storage period prescribed by other statutes.
nGle	Purpose: Consignment of customer service processing
	Items: Email, and personal information written by user in customer service
	Country / Method : South Korea / Transferred through the network when the service is used
	Contact: privacy@ngle.co.kr
	Retention Period: 3 years from the point of use of the customer inquiry
Metabora Singapore Pte. Ltd.	Purpose: NFT service-related business alliance and consignment of event operation
	Items: Game User Serial Number (GUSN), Name, Email, Blockchain Wallet Address
	Country / Method : Singapore / Transferred through the network when using the BORA PORTAL service and participating in events
	Contact: privacy@boraportal.com
	Retention Period: Until termination of events or it shall be subject to the storage period prescribed by other statutes. Until Member withdrawal or expiration or termination of the entrustment contract or it shall be subject to the storage period prescribed by other statutes.
Kakao Games Corp.	Purpose: Consignment of login platform development/operation, Consignment of BIRDIE SHOT game services
	Items : Information processed for service use, Google member identification number, game member number, device information (model name, OS version, country code, language)
	Country / Method: Korea / Transferred through the network when the service is used
	Contact: privacy_mobile@kakaogames.com
	Retention Period: Until Member withdrawal or expiration or termination of the entrustment contract or it shall be subject to the storage period prescribed by other statutes.

7. Retention and Destruction of Personal Data

As a rule, the Company destroys personal information immediately when the purpose of collecting and using personal data written in section 3 is achieved.

Personal information stored in electronic files is safely deleted using technical methods, and information printed on paper is shredded or incinerated to prevent it from being restored or regenerated.

However, if prior consent is obtained from the member or if there is an obligation to preserve it under the relevant laws, it will be stored safely in accordance with the relevant standards.

In the case of membership withdrawal, there is a 24-hour grace period after the membership withdrawal request for the purpose of resolving consumer complaints and disputes such as unwanted membership withdrawal caused by account theft. After 24 hours, the withdrawal request is completed, and personal information is stored for 7 days, and then destroyed in a way that cannot be reproduced.

8. Member’s Rights and How to Exercise Those Rights

Members can view or update their personal information at any time.

You can withdraw your consent to the collection and use of personal information at any time through ‘withdrawal of membership.’

Members can request these measures in this Privacy Policy “11. How to Contact”.

9. Protection of Children’s Personal Information

Unless permitted by applicable law, the Company does not knowingly collect or use Personal Information from Children under the age of 13 (or certain age otherwise defined under relevant law) or less, without consent of parents or legal representatives (such as guardians or others who have responsibility of a child)

If personal information is provided to the Company in the course of Service use, the Member himself/herself is guaranteed to be at the age of the standard. If the Company finds out that the personal information of Members under the age of 13 has been collected, the Company shall delete it through appropriate procedures.

Parents or legal representatives can contact the Company through "11. How to Contact " and request the deletion of children's personal information and accounts if they find that children under the age limits have subscribed to the Services or otherwise provided personal information to us.

10. Efforts for Privacy Protection

The Company is preparing the following technical and management measures to ensure safety so that personal data is not lost, stolen, leaked, tampered with, or damaged in processing Members' personal data.

- The Member's personal information is encrypted and stored. If such personal information needs to be transmitted, it is transmitted safely using encryption communication.

- The Company frequently backs up and manages important data to prevent personal information from being compromised and install and operate a vaccine program that updates regularly to prevent malicious code or virus infection.

- The Company minimizes the number of people in charge of handling personal information, and provides regular or regular training and campaigns for personal information handlers and executives and employees.

11. How to Contact

The Company has designated the Personal Information Protection Officer who will be responsible for answering the members’ inquiries regarding personal information and resolving any related complaints.

Additionally, If you are in the EU/UK, you can contact our Data Protection Officer designated by us.

- Personal Information Protection Officer and Data Protection Officer: Igoo Lee (CTO)

- Division in Charge: Personal Information Protection Part

- Phone No.: 82-31-607-6086
- Email: privacy.p2b@metabora.io

12. Responsibility for Linked Sites
The Company may provide Members with links to other external sites.

In such cases, the Company has no control over external sites and materials, so this Privacy Policy does not apply and cannot guarantee safety, etc. for the usefulness of the services or materials provided therefrom. If you click on the link that the Company contains to move to a page on another site, please check the
policies of the new site as the privacy policy of the site is independent of the Company.

13. Obligation to Notify Before Amendments

Members will be notified of any revisions to this Privacy Policy, including any newly added, deleted, or updated information, through ‘Notice’ at least seven (7) days prior to the amendments.

If it is difficult to notify within the prior notice date, we will notify you without delay.

Since this Privacy Policy can be checked at any time on the first screen of the Service website, Members are obligated to always check the latest version of the Privacy Policy at all times.