Welcome to Closed Beta Test of Synced: Off Planet!

This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with the Closed Beta Test for Synced: Off Planet (the “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 when requested and stop using the Game. By using the Game you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

This CBT 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 CBT is Proxima Beta Pte. Limited . The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore.

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

Our data protection officer can be contacted at 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.

1. The Types of Personal Information We Use

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:

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 CBT. If you set up your account using your Steam account information, we will collect your Steam nickname, Steam ID and Steam accomplishments. We will also automatically collect your OpenID as part of the registration process.

· Survey information: When you choose to participate in a survey in the CBT, we will collect your identity information (Open ID, Role ID, email address, gender, age), game experience, jobs, hobbies, game feedbacks, other optional information (occupation, income, behaviour, area (country)), and information that you provide in your response to the survey.

· Customer support information: When you provide information to our support team, or persons who provide support on our behalf when we connect with you on Discord, we collect information as necessary to resolve your issues including your Open ID, game information, system information, network information and details of your error.

2. Information about you generated as part of the CBT

We automatically collect certain data from you when you use the CBT, namely:

· Your IP address;

· your Open ID to send you in-game notifications about the CBT;

· your device information, including device name, device model, version of SDK, screen DPI, resolution and orientation, network type, RAM, ROM and CPU information;

· when you communicate with other users in the CBT (e.g., chat content and game data); and

· when you are using the CBT, the CBT will generate game data and our security feature collects (in addition to the categories of data listed above) device information including system version, network type, CPU architecture, system times, country code, remaining memory and space, and information relating to hacking and cheating software; and

· information processed by the GDOS proxy (Open ID, score, nickname, equipment, mail_title, iVipLevel, MailId, iPayPlayer) to connect with the front-end player console.

2. Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the CBT. 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.

3. Children

Children must not use the CBT for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries we have listed the relevant minimum age in the table below.

Country in which the user is located	Minimum age of the user
European Economic Area	16
Canada	13
United Kingdom	13
United States	13

We do not knowingly collect personal information from children under these ages 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.

4. How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the European Economic Area or United Kingdom (“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)
Information you provide to us (either directly or through a third party).
Account registration information: Open ID Via Steam: your Steam nickname, Steam ID and Steam accomplishments	We use this information to create your account for the CBT in accordance with your request.	Necessary to perform our contract with you to provide the CBT.
Survey information: Identity information (Open ID, Role ID, email address, gender, age), game experience, jobs, hobbies, game feedbacks, other optional information (occupation, income, behaviour, area (country)), and information that you provide in your response to the survey.	We use this information to conduct surveys to improve the CBT.	Consent.
Information generated as part of the CBT
IP location	We use this information to determine your location when you register for the CBT but we do not store this information.	N/A.
Notifications: Open ID	We use this information to send you in-game notifications about the CBT.	We use this information with your consent.
Chat Data (real-time voice audio): OpenID, device information (brand and manufacturer, name, client exports IP, UUID, system time) and other (SDK version, IP address, model and network type).	We use this information to facilitate your communications with other users.	Necessary to perform our contract with you to provide the CBT where you seek to use chat services.
CBT Game Data: · Identity Information: OpenID, RoleID, Game account (used by players when they log in to the CBT), User nickname · Device information: PC memory, CPU model, GPU information, CPU usage rate, Device brand, Network traffic, Device system version, UUID (Universally Unique Identifier), 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 · Gameplay statistics: (level, battle scores, battle actions, date and time stamp of actions)	We use this information to enable you to play the CBT and to undertake statistical analysis and quality monitoring.	It is in our legitimate interests to use this information to protect the integrity of the CBT and improve its operation.
Security-Related Information: · Open ID · Device information (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); · Whether root, whether it is running in the simulator, installed APK information, running process information, file name list under SD card application cache directory, application package name, process name, application version, startup time; and · Other (list of hack or cheating software, network type, in-CBT screen and information on suspicious rooting, host file, processes, APK or external applications).	We use this information： · For security and verification purposes, including to detect and observe cheating behaviours; · Identify and address bugs and assess game function for optimisation; and · Solve game crashes and optimise compatibility of devices with the CBT	It is in our legitimate interests to use this information to protect the integrity of the CBT and improve its operation.
Additional Security-Related Information (Anti-Cheating): device information (operating system and hardware information, debug tools, game file and memory data) and other (recent processes, modules and kernel drivers, cheating traces (e.g., extraction history), file and memory image samples, game memory samples, behaviour (e.g., system tampering), in-game data and security authentication (e.g., machine codes))	We use this information to fight against cheating and provide a fair environment.	It is in our legitimate interest to maintain a fair gaming environment within the CBT.
GDOS proxy: Open ID, score, nickname, equipment, mail_title, iVipLevel, MailId, iPayPlayer	We use this information to connect with the front-end player console to provide the CBT. We do not store this data.	Necessary to perform our contract to provide the CBT.

5. How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide you with 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 United States.

In addition, our support, engineering and other teams are located in Singapore and will have access to your information.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· 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.

· Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

· A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

6. The Security of Your Personal Information

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.

7. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
Steam account information	Open ID: stored for the lifetime of your use of the CBT, until account deletion in accordance with your request, upon which it will be deleted within 30 days. Other information other than Open ID: stored for 30 days from the date the you last log in.
Survey Information	Stored for 365 days following receipt of the data. The data is deleted upon the expiry of such period or within 30 days of a lawful request from you for the erasure of such data (whichever is sooner).
CBT Game Data	Stored for the lifetime of your use of the CBT and then for 60 days. Where you request to delete your account, we will delete your information within 30 days.
Chat Data (Real-time audio data)	Stored for the duration necessary to transmit the Chat Data to other users and then deleted.
Security-Related Information	Stored for 90 days following receipt of the data. The data is deleted upon the expiry of such period or within 30 days of a lawful request from you for the erasure of such data (whichever is sooner).
Additional Security-Related Information (Anti-Cheating):	We generally retain this data for no longer than 30 days with the exceptions listed below. · File and memory image samples: 7 days or, if confirmed malicious, up to 3 years; · CBT memory sample: 60 days or, if confirmed malicious, permanently; · Behaviour: 90 days; · In-CBT data and system information: Stored for the lifetime of your use of the CBT (i.e. until account deletion in accordance with your request) and then for 30 days. · Security authentication: 730 days. The data is deleted upon the expiry of such period or following a lawful request from you 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.
Notification information	30 days.

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.

8. Your Rights

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.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada.

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., CBT data), 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 CBT 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 CBT 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 CBT 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 CBT 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.

9. Contact & Complaints

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 country in which you live or work where you think we have infringed data protection laws.

10. Changes

If we make any material 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.

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:

· Identifiers, such as your name as it appears on your Steam profile, Open ID / user ID, IP address, device ID. This information is collected directly from you and your device and from social media platforms if you choose to sign up using your Steam account.

· Internet or other electronic network activity information, such as your information regarding your use of the CBT other Device Information as described in the main Privacy Policy. This information is collected directly from you and your device.

· Audio information audio messages. This information is collected directly from you when you communicate with other users in the CBT.

· Other information described in subdivision (e) of Section 1798.80, including information about your gender, nationality, or age. This information is collected directly from you in the context of being our consumer.

We collect your personal information for the following purposes:

· To provide you with the CBT, maintain your account, and deliver audio messages.

· To process surveys.

· To improve our services, including the functionality of the CBT.

· For security and verification purposes, including to prevent and detect fraudulent activity.

· To address and remediate technical issues and bugs.

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:

· Other companies within our corporate group who process your personal information in order to operate the CBT.

· Other companies that provide services on our behalf in support of the CBT and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.

· Regulators, judicial authorities and law enforcement agencies

· Entities that acquire all or substantially all of our business.

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:

· Request we disclose to you free of charge the following information covering the 12 months preceding your request:

o the categories of personal information about you that we collected;

o the categories of sources from which the personal information was collected;

o the purpose for collecting personal information about you;

o the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

o the specific pieces of personal information we collected about you;

· Request we delete personal information we collected from you, unless CCPA recognises an exception; and

· Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

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.

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at dpo_syncedoffplanet@proximabeta.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

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.