Synced
Off-Planet – Recruitment Survey and Closed Beta Test
Privacy
Policy
Last
Updated: 13 April 2022
Thank you for using our products and services! We
respect your concerns about privacy and appreciate your trust and confidence in
us.
Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.
What
information do we need to provide the Game?
If you register your interest for the
Closed Beta Test, we will need to collect your IP address, Discord ID, age
group and email address. If you register an account to participate in the CBT, then we will need some information from you to set this
up. When you set up your profile using Steam, we also collect information,
including your email address, Open ID, nickname and Steam ID, from the Steam
account. If
you choose, you can provide certain other information to personalise your experience of the CBT,
participate in surveys about the CBT, enable CBT features
or participate in the CBT. If you need to get in touch with us, we
will retain some information so that we can get back in touch with you and
address any concerns. More Information.
How will we use
your information?
We use your information to send
you a link to the CBT (if you are verified as eligible to participate), and to provide
the
many functions and services that comprise the CBT. We also use your information for account verification,
security purposes and to support and improve the
Game. We
do not share your information with any third parties, except where we need to
in order to provide the CBT (e.g., use our affiliates around the world to help
us to deliver the CBT) or where we are instructed to by a court, authority or
compelled by law. More Information.
Who
do we share your information with?
We
have affiliates around the world who help us deliver the CBT and we may be
required by a court or legal obligation to disclose certain information in some
circumstances. More Information.
Where
do we process your information?
Our servers are located in Germany, Singapore, and the United States. Your information can
be accessed from outside of where you live by our support, engineering and
other teams around the world, including Singapore (“PRC”). More Information.
How
long do we keep hold of your information?
We generally retain your information for 30 days after
the CBT, after which time
your data is deleted (as further described in this Privacy Policy), unless
otherwise required by applicable laws. More
Information.
How
can I exercise my rights over my information?
Depending on where you are, you may
have certain rights with respect to your information, such as rights of access,
to receive a copy of your data, or to delete your data or restrict or object to
our processing of your data. More Information.
If you have any questions about
anything in this Privacy Policy, or want to exercise any rights you may have,
please contact us here.
How will we notify you of changes?
Changes to this Privacy Policy
will be posted here. Please check this page frequently to see if there are any
updates or changes to this
Privacy Policy. More Information.
Data Controller: Proxima Beta Pte. Limited | Email:
dpo_syncedoffplanet@proximabeta.com
EU Representative:
Proxima Beta Europe B.V. | Email: dpo_syncedoffplanet@proximabeta.com
UK Representative: Image Frame Investment (UK)
Limited | Email: dpo_syncedoffplanet@proximabeta.com
Welcome to Synced Off-Planet Recruitment Survey and Closed
Beta Test!
This Privacy Policy
explains the when, how and why when it comes to the processing of your personal information in connection with Synced Off-Planet (the “Game”) Closed Beta Test (“CBT”), and
sets out your choices and rights in relation to that information. Please read
it carefully – it is important for you to understand how we collect and use
your information, and how you can control it.
If you
do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information or
register your interest to participate in the CBT through the CBT recruitment
survey (“Recruitment Survey”) or participate in the
CBT. By providing your details through the Recruitment Survey and participating
in the CBT, you are acknowledging our rules regarding your personal information
as described in this Privacy Policy.
This Game has been
developed by Proxima Beta Pte. Limited (“we”,
“us”, “our”).
For the purpose of data protection laws, the data controller of your personal
information in relation to the Game is Proxima Beta Pte.
Limited. The
registered address of Proxima Beta Pte. Limited is 10
Anson Road #21-07 International Plaza, Singapore.
Our data protection officer can be
contacted at dpo_syncedoffplanet@proximabeta.com.
Our representatives for data
protection purposes in certain jurisdictions are as follows:
Jurisdiction |
Representative |
Address |
Contact details |
EU |
Proxima Beta Europe B.V. |
Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands |
dpo_syncedoffplanet@proximabeta.com |
UK |
Image Frame Investment (UK) Limited |
Suite 1, 3rd Floor 11 - 12 St. James's Square, London,
United Kingdom, SW1Y 4LB |
dpo_syncedoffplanet@proximabeta.com |
Please reach out to
us if you have any questions or concerns regarding the processing of your
personal information. You can contact us anytime at dpo_syncedoffplanet@proximabeta.com.
This section describes the
different types of personal information we collect from you and how we collect
it. If you would like to know more about
specific types of data and how we use that data, please see the section
entitled “How We Use Your Personal Information”
below.
The following is a high-level summary
of the types of personal information we use:
Recruitment
Survey
If you register your interest to
participate in the CBT through the Recruitment Survey, we will collect your IP
address, Discord ID, age group and email address. We use this information to
verify your eligibility to participate in the CBT and send you a link to the
CBT (if you are eligible).
CBT
1. Information you provide to us
(either directly or through a third party).
·
Account registration information: You
give us information about you when you set up an account to register for the Game
using Steam: your Open ID, Steam nickname, Steam ID and email address in order
to set up your profile.
·
Survey information: If you choose to
participate in a survey about the Game, you may be asked to provide certain
personal information, such as your email address, gender, age, game experience,
game feedbacks and other optional information such as in-Game actions and behaviour,
area, and any other content you choose to provide as part of the survey
response.
2. Information about
you generated as part of the CBT
We
automatically collect certain data from you when you participate in the CBT, namely:
·
Notice: your open ID to send you
in-game notifications;
·
Chat data (audio): information such as your open ID, device name, device model, client
exports IP, device brand, UUID, device manufacturer, system time, SDK version,
IP address, network type, and device model to allow users to communicate through real-time voice chat;
·
Game data: identity information,
device information and gameplay statistics to enable users to play the Game and
for us to undertake statistical analysis and quality monitoring;
·
Security information and additional security information: to fight against cheating and to
provide a fair gameplay environment;
·
Customer service
information (GDOS):
GDOS is a proxy which provides a connection between the underlying game data
and front-end interface (PlayerConsole) to enable game operation and customer
service personnel to access, amend and delete information relating to users in
the Game. Game user role information, such as open ID, score, nickname,
equipment, mail title, iVip level, Mail ID, iPayPlayer; and
·
IP country.
We use cookies and other
similar technologies (e.g. web beacons, log files,
scripts and eTags) (“Cookies”) to
enhance your experience using the Game. Cookies are small files which, when
placed on your device, enable us to provide certain features and
functionalities.
For more information about
our Cookies policy, click here.
The CBT is only available for users aged 16 or over.
We do not knowingly collect personal information from children for any purpose.
If you believe that we have personal information of a child under these ages
without parental/guardian consent, or if you are the parent or guardian of the
user and wish to withdraw consent, please contact us at
dpo_syncedoffplanet@proximabeta.com and
we will delete such information.
This section provides more detail on the types of personal
information we collect from you, and why. For users who live in the United
Kingdom and the European Economic Area (“Relevant
Jurisdiction”), it also identifies the legal basis under which we process
your data.
Personal
Information |
Use |
Legal Basis (only
relevant if you are located in a Relevant
Jurisdiction) |
Recruitment
Survey |
||
Recruitment survey information: IP
address, and information you provide as part of the survey response (via
Alchemer) (including your Discord ID, age group, email address) |
We use
this information to verify your eligibility to participate in the CBT and
send you a link to the CBT (if you are eligible). |
Necessary
to perform our contract with you to provide the CBT. |
CBT |
||
Information
you provide to us (either directly or through a third party) |
||
Account creation/ verification/ log in: Open
ID, Steam nickname and Steam ID,
email address |
We
use this information to create your account for the Game and log in using
Steam in accordance with your request. |
Necessary
to perform our contract with you to provide the CBT. |
Survey information (via IMUR): email
address, gender, age, game experience, game feedbacks, other optional
information (such as in-Game actions and behaviour, area), and any other
content you choose to provide as part of the survey response. |
We use
this information to conduct surveys to better understand our users and to
improve the Game. |
We use
this information with your consent. |
Information generated as part of the CBT |
||
Notice: Open ID |
We use
this information to send you in-game notifications about the Game. |
Necessary
to perform our contract with you to provide the CBT. |
Chat data (audio): ·
Identity
information: open ID; ·
Device
information: device name, device model, client exports IP, device brand, universally
unique identifier (UUID), device manufacturer, system time; and ·
Other: SDK version,
IP address, network type, and device model. |
We use
this information to facilitate your communications with other users through
real-time voice chat. Please
note that this data is only stored on your device, and
is not processed by our servers. |
N/A |
Game data: ·
Identity
Information: open ID, role ID, Game account, user nickname; ·
Device
information: PC
memory, CPU model, GPU information, CPU usage rate, device brand, network
traffic, device system version, UUID, client exports IP, WiFi SSID, device
language, screen resolution, ROM, device manufacturer, screen orientation,
RAM, Wifi address, device name, device standard, disk information, device
model, system time, sensor information, host file, CPU architecture,
remaining memory, system startup time; and ·
Gameplay
statistics: level, battle scores, battle actions, and date and time stamp of
actions. |
We use
this information to enable you to participate in the CBT and to undertake
statistical analysis and quality monitoring. |
Necessary
to perform our contract with you to provide the CBT. |
Security-related information: ·
Open ID; ·
For
Android: system version, network type, brand, CPU architecture, ROM unique
identifier, device screen resolution, system boot time, country code and
language, remaining memory, remaining built-in and external SD card space,
Root status, simulator status, installed APK information, running process
information, file name list under SD card application cache directory,
application package name, process name, application version, startup time,
host file, in-game screen; ·
For iOS: in-game
screen, system version, network type, brand, CPU architecture, language
region, RAM space size, ROM space size, system startup time, whether the
external file is detected, application package name, application version,
startup time, in-game screen, and process name. |
We use
this information to: ·
For security and verification purpose, including
to detect and observe cheating behaviours; ·
Identify and address bugs and assess game
function for optimisation; and ·
Solve crashes and optimise compatibility of
devices. |
It is in
our legitimate interests to use this information to protect the integrity of
the Game and improve its operation. |
Additional security information: ·
Device
information: operating system and hardware information, debug tools, game file and
memory data; ·
Other: recent
processes, modules and kernel drivers, cheating traces, file and memory image
samples, game memory samples, behaviour, in-game data and security
authentication. |
We use
this information to: ·
provide a fair environment; and ·
detect and fight against cheating. |
It is in
our legitimate interests to use this information to protect the integrity of
the Game and improve its operation. |
Customer
service information (GDOS): open ID, score, nickname, equipment, mail
title, iVipLevel, Mail ID, iPayPlayer. |
We use
this information to connect with the front-end player console to provide the
Game. We do not
store this data. |
Necessary
to perform our contract with you to provide the CBT. |
IP: IP location |
We use
this information to determine your location when you register for the CBT. We do not
store this data. |
Necessary
to perform our contract with you to provide the CBT. |
Our
corporate group operates around the world. Pursuant to
our contract with you to allow you to register your interest to participate
in the CBT through the Recruitment Survey and to allow you to sign up for and
participate in the CBT, your personal information will be processed on servers
that may not be located where you live. No matter where our servers are
located, we take appropriate measures to safeguard your rights in accordance
with this Privacy Policy. Our servers for
the CBT are
located in
Germany, Singapore and the United States.
In addition, your information can
be accessed from outside of where you live by our support, engineering and
other teams around the world, including Singapore.
Only where
necessary
will we share your personal information with third parties. Situations where this occur are:
·
Third parties that provide services in support of the Recruitment Survey and CBT. All
companies providing services for us are prohibited from retaining, using, or
disclosing your personal information for any purpose other than providing us
with their services;
·
Companies within our corporate group who
process your personal information in order to operate the CBT. All related
group companies may only use your personal information in accordance with this Privacy
Policy.
We are committed to maintaining the privacy
and integrity of your personal information no matter where it is stored. We
have information security and access policies that limit access to our systems
and technology, and we protect data through the use of
technological protection measures such as encryption.
Unfortunately, the
transmission of information via the internet is not completely secure. Although
we will implement and maintain reasonable measures to protect your personal information,
we cannot guarantee the security of the information transmitted through the CBT
or otherwise via the Internet; any transmission is at
your own risk.
Personal
Information |
Retention Policy |
Recruitment survey |
|
Recruitment survey information |
Stored for 30 days after the CBT ends, unless account deletion in
accordance with your request, upon which it will be deleted within 30 days. |
CBT |
|
Account creation/verification/log-in |
Open ID
is stored for the lifetime of your use of the Game (i.e.
until account deletion in accordance with your request, upon which it will be
deleted within 30 days). Information
other than open ID will be stored for 30 days after the CBT ends, unless
account deletion in accordance with your request, upon which it will be
deleted within 30 days. |
Notice information Survey information Game data Security data Additional security information |
Stored for 30 days after the CBT ends, unless account deletion in
accordance with your request, upon which it will be deleted within 30 days. |
Chat data (audio) |
This data is only processed and stored on your device,
and is not processed by or stored on our servers. |
Customer service information (GDOS) IP country |
This data
is not stored. |
The data is deleted upon the expiry of such period or following a lawful
request from users for
the erasure of such data. Upon a lawful request, we will delete the data within
30 days except where they relate to confirmed malicious activities.
If we are required to retain your information beyond
the retention periods set out above, for example to comply with applicable
laws, we will store it separately from other types of personal information.
Some
jurisdictions’ laws grant specific rights to users of the CBT, which are set
out in this section.
This section
entitled “Your Rights” applies to users that are located in
the Relevant Jurisdictions. If you are located in a
territory outside a Relevant Jurisdiction, please refer to the Supplemental
Jurisdiction-Specific Terms for an overview of your rights and how these can be
exercised.
You have certain rights in relation to
the personal information we hold about you, depending on where you are located.
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 dpo_syncedoffplanet@proximabeta.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 account. If you believe we hold any other personal
information about you, please contact us at dpo_syncedoffplanet@proximabeta.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 (e.g., survey
information) or pursuant to our contract with you (e.g., account name), as
described above 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, with
certain exceptions. We will provide further information to you about this if you make
such a request.
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 (for example, 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 of your personal information we
hold that is inaccurate. You can access the personal information we hold about
you 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 dpo_syncedoffplanet@proximabeta.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 dpo_syncedoffplanet@proximabeta.com.
We may need to retain personal
information if there are valid grounds under data protection laws for us to do
so (for example, 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 (for example, 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.
Objection
You have the
right to object to our processing of your personal information. We will
consider your request in other circumstances as detailed below
by contacting us at dpo_syncedoffplanet@proximabeta.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 dpo_syncedoffplanet@proximabeta.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 (for example, when we
temporarily suspend access to the Game 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.
Questions, comments and
requests regarding this Privacy Policy are welcomed and should be addressed to dpo_syncedoffplanet@proximabeta.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 dpo_syncedoffplanet@proximabeta.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 region in which you live or work where you think we have infringed
data protection laws.
If we make any changes to
this Privacy Policy we will post the updated Privacy
Policy here. Please check this page frequently to see if there are any updates
or changes to this Privacy Policy.
Except as otherwise
prescribed by law, in the event of any discrepancy or inconsistency between the
English version and local language version of this privacy policy, the English
version shall prevail.
SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC
Some jurisdictions’ laws
contain additional terms for users of the CBT, which are set out in this
section.
If you are a user located
in one of the jurisdictions below, the terms set out below under the name of
your jurisdiction apply to you in addition to the terms set out in our Privacy
Policy above.
California
This section applies to
California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).
Collection and
Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed the
following categories of personal information from or about you or your device:
We collect your personal information for
the following purposes:
For additional information about what each type of personal information
is used for, see this chart in the main portion of the Privacy Policy.
We disclose personal information to the
following types of entities:
In the past 12
months, we have not sold Personal Information of California residents within
the meaning of “sold” in the CCPA.
Rights
under the CCPA:
If
you are a California resident, you have the right to:
We
aim to fulfil all verified requests within 45 days pursuant to the CCPA. If
necessary, extensions for an additional 45 days will be accompanied by an
explanation for the delay.
How
to Exercise Your Rights
First, you may wish to log into your
account and manage your data from there. If you are a California resident
to whom the CCPA applies, you may also exercise your rights, if any, regarding
other data by contacting us at dpo_syncedoffplanet@proximabeta.com.
France
Your Rights
Instructions for the processing of your
personal data after your death
You have the right to provide us with general or specific
instructions for the retention, deletion, and communication of your personal
data after your death.
The
specific instructions are only valid for the processing activities mentioned
therein and the processing of these instructions is subject to your specific
consent.
You
may amend or revoke your instructions at any time.
You
may designate a person responsible for the implementation of your instructions.
This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from
us. In the absence of designation or, unless otherwise provided for, in the
event of the death of the designated person, their heirs will have the right to
be informed of your instructions and to request their implementation from us.
When you wish to make
such instructions, please contact us at dpo_syncedoffplanet@proximabeta.com.