PRIVACY POLICY (Outside EU)

EFFECTIVE DATE: 2019.05.01
Polycube Corporation (“Polycube") respects the privacy rights of its customers and protects the personal information collected, stored and used in connection with Polycube Corporation products, services and websites (the "Services"). To further this commitment, we have adopted this Privacy Policy ("Privacy Policy") to guide how we collect, store, and use the information you provide us.

I. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy describes Polycube 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.

II. INFORMATION COLLECTED

We may collect and process the following data about you.
- Personal Information
When you engage in certain activities in the website or access the Services (such as registering a user account, downloading and installing application(s), playing game(s), purchasing virtual game items, sending and/or posting a user content, or sending us feedback), Polycube may collect information about you, but only if you voluntarily provide it to us. The requested Personal Information may include, but are not limited to your email address, photo or other images.
- Usage Information
We collect details of your use of our Services and the resources that you access. Such usage information include information about how and when you access or use our Services (such as games accessed, pages visited, purchase and use of virtual game items, the details of your purchases, and your game play).
- Technical Information
We collect general technical data pertaining to you (such as information about the device you use to access our Services, IP address, operating system, browser type, program or system error messages and other system information).
- User Communication with Polycube
If you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence.
- Information from Third Party Social Networks or Platforms
You may allow our Services to interact with a third party social network or platform, such as Facebook, which will provide data about you to us. These applications or websites are created and maintained by a third party which is not a part of, or controlled by us. You should ensure that you read their terms of service and privacy policies to understand how they treat your data and what data they might share with us.
- Non-Personal Information
For purposes of this Privacy Policy, "Non-Personal Information" means information that does not directly identify you. Polycube may use tools or third party analytical software to automatically collect and use certain Non-Personal Information that does not directly enable Polycube to identify you.
- Cookies
The Services may use cookies and other technologies such as pixel tags, locally shared objects and web beacons to collect technical information and usage data, which may be linked and identified with your account. A "cookie" is a small bit of record-keeping information that sites often store on a user's computer. You can disable cookies or set your browser to alert you when cookies are being sent to your computer, although this may affect your ability to login and use our Services.

III. USE AND SHARING OF INFORMATION COLLECTED

Use of Information Collected
Polycube may use your Personal Information to send you messages about our company or our features, products or services, or promotional material from some of our partners, or to contact you when necessary, unless you have not consented to allow Polycube to use your data.
Polycube also may use your Personal Information and Non-Personal Information, both individually or combined together, for editorial and feedback purposes, for marketing and promotional purposes, for statistical analysis of users' behavior, for product development, for content improvement, for customer support and technical support, to manage and provide the Services, and to customize content and layout of the Services.
Names, postal and e-mail addresses and phone numbers collected may be added to our databases and used for future calls and mailings regarding site updates, new products and services, and upcoming events.

Sharing of Information Collected
Polycube does not sell or rent your Personal Information to third-parties for marketing purposes without your consent. However, you hereby agree that Polycube may, without seeking further your consent, share your Personal Information with affiliate companies of Polycube to provide you Services or information about Services or other promotional materials. In addition Polycube may share Personal Information with business partners that assist Polycube in providing you Services Polycube is committed to giving you a choice when your Personal Information may be used or disclosed for marketing purposes.
We will encourage our service partners to adopt and post privacy policies. However, the use of your personally identifiable information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.
Interactions with Third Party Social Networks or Platforms: You understand that where you allow your account with us to interact with any third party social network or platform, we may share data about you with your contacts (and vice versa) in order that you may enjoy playing socially. This data includes your name, your social media profile, picture and your scores and/or progress in our games.
Business Transfer: In a business transaction, such as a merger, acquisition, dissolution (including bankruptcy), change of control, or a sale of all or a portion of our assets, customer information, including personally identifiable information, generally is one of the transferred business assets. In the event that Polycube undergoes such transactions, including preparation of any of such transactions, we may share, disclose or transfer all of your information, including personal information, to the successor. Any third party to which we transfers or sells our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.
Compliance with Legal Obligations: Occasionally we may be required by law enforcement or judicial authorities to provide Personal Information to the appropriate governmental authorities. We will disclose Personal Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation.

IV. COLLECTION AND USE OF CHILDREN'S PERSONAL INFORMATION

Our Services are not intended for children under the age of 13, and we do not knowingly collect any personal information from such children. Children under the age of 13 should not use or attempt to use our Services, and if you are under 13, please do not attempt to use our Services or send any information about yourself to us.
Further, in the event that Polycube receives personal information that Polycube discovers was provided by a child under the age of 13, Polycube will promptly delete such personal information in a secure manner. Parents, who believe that we might have any information from or about a child under 13, may submit a request in writing to master@polycube.co.kr that the information be removed.
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 Agreement 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.

V. SAFEGUARDS

Polycube maintains appropriate safeguards that ensure the security, integrity, and privacy of the personal information we collect and store about our account holders. Personal information collected by Polycube is stored in secure operating environments that are not available to the public and that are only accessible by authorized employees. In addition, our online store uses industry-standard encryption to prevent unauthorized electronic access to sensitive financial information such as your credit card number. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control (i.e., maintain data quality). Before we allow web users to access their personal information, for example, we verify their identity by requesting that they submit information such as their username and password. We also take reasonable steps to ensure that third parties to whom we transfer personal information provide sufficient protection of such data.
Your personal information may be transferred to, and stored at, a destination outside the country from which you accessed the Services. It may also be processed by personnel of our affiliates and third party service provider who may operate outside the country from which you accessed the Services. In such case, we will take reasonable steps to require such third party in possession of your personal information to take commercially reasonable security measures to protect the information.
However, unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personally identifiable information, you acknowledge that: (a) the security, integrity and privacy of any and all information and data exchanged between you and us through our Services cannot be guaranteed; and (b) any such information and data may be viewed or tampered with in transit by a third party

VI. LINKS TO THIRD PARTY SITES OR SERVICES

You should be aware that the Services may from time to time contain links to third-party sites, products or services. Polycube is not responsible for the privacy practices or the content of such sites or services. If you are concerned about the privacy policy of a certain third party, we recommend that you read the privacy policy of the site or service to which you link before you submit any personal information.

VII. ACCESS TO PERSONAL INFORMATION

Polycube makes good faith efforts to enable you to review, update or correct your personal information in Polycube 's possession. In order to do so, please contact our Privacy Policy Administrator at master@polycube.co.kr . Polycube will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request. Please note that even if personal information is changed or deleted according to your request, Polycube may still retain some of your personal information to resolve disputes, enforce Polycube user agreement(s), and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Services.

VIII. Deactivated or Terminated Account.

Please be aware that even after your account is terminated or deleted, some or all of your information may still remain visible to others. A request to delete and/or termination of your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us. We are not able and/or obligated to remove any of your information from a third party platform. Moreover, please be aware that even after you delete your account or your account is terminated, your information may not be deleted in its entirety from our servers and servers of the third party with whom such information have been shared.

IX. Inquiries.

If you have questions about this Privacy Policy or your privacy, please contact us at:
Email: master@polycube.co.kr

Privacy Policy (EU Only)

EFFECTIVE DATE: 2019.05.01
Your Privacy is important to us.
Polycube Corporation(“Polycube”, “We”, “Our”, or “Us”) respects your privacy right and protects your personal information processed in our products, games, services and websites(collectively, the “Services”). We adopted this Privacy Policy (“Privacy Policy”) as a guide pursuant to which we collect, store, and use your information.

TABLE OF CONTENTS

1. Scope of This Privacy Policy
2. Information We Collect
3. How We Use Your Information
4. Cookies and Similar Technologies
5. Information We Share with Third Parties
6. Children
7. Transfer of Your Data to Third Country
8. Your Choices and Controls
9. Security Safeguards
10. How to Contact Us and Your Right to Contact a Protection Authority

1.Scope of this Privacy Policy

This Privacy Policy describes what information we collect and how we use it, when you use our Services”.
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.
We may update this policy from time to time, so please review it frequently. We'll notify you of changes to this policy via a notice on our web site or other prominent means.
If we are required by applicable data protection laws to give you enhanced notice or seek your consent to any such changes, we will do so.
Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

2.Information We Collect

* Information You Give Us Directly

• When you use the Service, your username
• When you contact us, your email address, username, attached file.
• When you sign up for the newsletter, your email address

* Information We Collect Automatically

We collect information automatically when you use our service.
• What Service you use and your use of them, game play data
• Purchase and use of virtual game items and the details of your purchase
• Device event information, including crash reports, error messages and other system information
• IP address and mobile device identifiers (such as your device ID, advertising ID, IDFA)
• Device information, such as device name, operating system and browser type, telecommunication company, hardware settings and components
• Referring and exit pages, including landing pages and pages viewed
• Platform type, language you prefer, county code
• Cookies
We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage and application data caches. In most cases, we also create a Polycube-specific ID for you when you use the Service. If you contact us or respond to messages that we sent you, we may keep a record of that correspondence.

* Information We Collect from Third Party

We may receive your ID and username, if any, from third parties when you use our Services through your accounts in such parties, including Facebook, Google, and Payco. You should read their Terms of Service and Privacy Policies to understand how they treat your data and what data they might share with us.

* Legal Basis for Processing

If you are a resident of the European Union or the European Economic Area, we rely on a number of legal grounds to process information about you. Such legal grounds may include, without limitation, your consent to such processing, our legitimate interest to process your information, the necessity of such processing in order for us to perform under a contract with you, and our legal obligation to process your information. To learn more about the legal grounds on which we rely to process your information, please contact us via the options in Section 8. Your Choices and Controls below.

3. How We Use Your Information

To make the Service work

Create accounts and allow you to play our games and use our Services

• Operate, improve, and develop the Service
• Verify and confirm payments
• Provide and deliver products and services you request
• Send you service-related communications
• Help you find your friends or tell your friends about the Service

To Make the Service more suitable for our users

To provide a great Service to our users, we have a legitimate interest to collect and process information to

• Develop and improve the Service and user experience
• Customize your Service experience
• Respond to your comments and questions and provide user support
• Send you related information, such as updates, security alerts, and support messages
• Enable you to communicate with other users

To keep the Service safe and fair

Ensuring a level playing field in the Service is a top priority for us. For more information on our policy on acceptable use of our Services, see the Terms of Service.

In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary information to

• Analyze and monitor use of the Services and its social features
• Take action against fraudulent of misbehaving users

To show personalized advertisements (“for marketing and promotional purposes”)

To show you personalized advertisements in the Service as well as in other websites and services (including email) we have a legitimate interest to process necessary information to

• Track the content you access in connection with the Service and your online behavior
• Deliver, target and improve our advertising and the Service

For information on how to opt-out from personalized advertisements, see section Section 8. Your Choices and Controls below.

4.Cookies and Similar Technologies

A cookie is a small text file that a website saves on your computer or mobile device when you visit the website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie, to develop a record of the user’s online activity.

We use cookies and other technologies as pixel tags, locally shared objects and web beacons to provide and personalize the Service, analyze use, target advertisements and prevent fraud.

This information helps us measure the effectiveness of our advertising, make sure you don’t see the same ad repeatedly and otherwise help enhance your user experience. You can disable cookies or set your browser to alert you when cookies are being sent to computer, although this may affect your ability to login and use our Services.

We use other technologies for similar purposes as a cookie. We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our Services, troubleshoot technical problems, detect and prevent fraud.

5.Information We Share with Third Parties

We do not share personal information that directly identifies you (such as your name, email address or postal address) with third parties for their own use without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, property or operations or to protect our users or third parties.

We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties.

The Service includes features from our partners, such as social networks of platforms. These partners may access your personal data and operate under their own privacy policies. We encourage you to check their Privacy Policies to learn more about their data processing practices.

However, in the event of a reorganization, divestiture, merger, sale or bankruptcy, we may transfer all information we collect to the relevant third party. The third party will have the right to use the transferred information, unless the law requires your consent.

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.

We employ third parties located in and outside of your country of residence (including outside of the European Union (EU) or the European Economic Area (EEA)) to collect or process personal information on our behalf for various reasons, such as conducting market surveys, facilitating credit card processing, or sending emails. When our third party agents or service providers collect or receive personal information, we require that they use the data only on our behalf and for purposes consistent with this policy.

Our Services may contain advertising or third party services (such as the Facebook Like button or links to third-party websites). If you click on those links, including an advertisement, you will leave the Service and go to the site you selected. If you visit a third party website or use a third party service, you should consult that site's or service's privacy policy.

We do not control information sent from your browser to third parties, such as advertising networks and analytics companies that receive information in the normal course of your Internet activity. When third party technologies or social tools are integrated into our products, those third parties may collect information when you use our products.

6.Children

We are committed to protecting personal data of children and we hold their online privacy to be a matter of extreme importance. When we say children, we mean persons under the age of 16 or the minimum age in the relevant territory if such age is older than 16.

Many of our services are intended for general audiences and we do not knowingly collect any personal information from children. When users identify themselves as being children we will obtain consent from the holder of parental responsibility over the children for the use of the children's personal information, all according to applicable law.

If you are a parent and wish to revoke your previously provided consent, review information collected from your child, cease processing or profiling of your child’s personal data for the purpose of direct marketing, or have that information deleted, please contact master@polycube.co.kr.

7.Transfer Your Data to a Third Country

Your information we collect may be stored and processed for the purposes set out in this Privacy Policy in South Korea or any other country in which Polycube, its subsidiaries, or third party agents operate. In particular, we will obtain your explicit consent when your personal data is transferred to South Korea and, in certain circumstances for the purpose of contractual performance, to other countries.

By using our services, you acknowledge that your personal information may be transferred to recipients in South Korea and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

In all cases, appropriate security measures for the protection of personal information will be applied in those countries or territories.

8.Your Choices and Controls

We give you meaningful choices when it comes to important uses and collection of information.

Your privacy rights.

You have the right to access and correct your information, have your information deleted, object how we use or share your information, restrict how we use or share your information, withdraw your consent, and request to transmit your information to other controller. You can always exercise your rights mentioned above, by contacting us at master@polycube.co.kr

We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you can also contact your local data protection authority within the European Union or the European Economic Area for unresolved complaints.

For the details of your rights, see the table below

Right to Access

You shall have the right to obtain from us whether or not your personal information is being processed, and access to the following information:

(a) the purpose of the processing; (b) the categories of persona information concerned; (c) the recipient or the categories of recipient to whom the personal information have been or will be disclosed; (d) the envisaged period for which the personal information will be stored, or the criteria used to determined that period; (e) the existence of the right request rectification; (f) the right to lodge a complaint with a supervisory authority; (g) where personal information are not collected from you, any available information as to their source; (h) the existence of automated decision-making, including profiling.

Right to Rectification

You shall have the right to have any inaccurate personal information about you rectified and incomplete personal information completed.

Right to Erasure

You shall have the right to erase your personal information in certain circumstances. Those circumstances include:

(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) you withdraw consent to consent-based processing; (c) you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and (iv) the personal data have been unlawfully processed.

There are exceptions to exercise the rights:

(a) for exercising the right of freedom of expression; (b) for compliance with the public interest; or (c) for the establishment, exercise or defense of legal claims.

Right to Restrict Processing

You have the right to restrict processing your personal information in following circumstances:

(a) you contest the accuracy of the personal information; (b) processing is unlawful but you oppose erasure; (c) we no longer need the personal information for the purposes of our processing, but you require personal information for the establishment, exercise or defense of legal claims; and (d) you have objected to processing, pending the verification of that objection.

Where processing has been restricted on this basis, we may continue to store your personal information. However, we will only otherwise process it: (a) with your consent; (b) for the establishment, exercise or defense of legal claims; (c) for the protection of the rights of another natural or legal person; or (d) for reasons of important public interest.

Right to Data Portability

You have the right to receive your personal information, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, where:

(a) the processing is based on your consent; (b) the processing is necessary for the performance of a contract; (c) the processing is carried out by automated means.

Right to Object to Processing

You have the right to object to our processing of your personal information on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: (a) the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; (b) the purposes of the legitimate interests pursued by us or by a third party; (c) the direct marketing purposes; or (d) the scientific or historical research purposes or statistical purposes.

If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims

Right to Object and Automated Individual Decision-making

You shall have the right not to be subject to a decision based solely on automated processing, include profiling, which produces legal effects similarly significantly affects to you.