Last Updated: 09 July 2026
Thank you for attending the PUBG Mobile x Naruto Shippuden AI Image-to-Image Group Photo Event! This Privacy Policy explains the when, how, and why when it comes to the processing of your personal information in connection with this event (the “Event”), and sets out your choices and rights in relation to that information.
For the purposes of data protection laws, the data controller of your personal information in relation to the Event is Proxima Beta Pte. Ltd. (“we”, “us”, “our”).
What is PUBG Mobile x Naruto Shippuden AI Image-to-Image Group Photo Event? The Event allows you to submit reference images (such as photos), and other instructions (“Inputs”) via our online platform (“Platform”), which are processed in accordance with your instructions to generate AI-created content such as images, delivered back to you (“Outputs”). To provide Outputs, we rely on various third party LLM providers to provide Outputs. When providing input to Platform, please do not disclose any of your sensitive personal information or information of others. Any information you include in your reference images may be processed by the relevant LLM and reproduced in Outputs. |
Please note that this Privacy Policy only applies to the Event. If you use any other products, services or Events, please refer to the privacy policy for that particular product, service or Event.
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 Event. By using the Event you are acknowledging how we process your personal information as described in this Privacy Policy and, to the extent performance of a contract or legitimate interest cannot be relied upon in your jurisdiction to process the personal information, you consent to the processing of your personal information as described in this Privacy Policy.
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found in Section 7 (Contact) below.
Children must not join the Event for any purpose. By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age (“Minimum Age”). We do not seek nor knowingly collect personal information from children under the Minimum Age for any purpose. If you believe that we have personal information of anyone under the Minimum Age, or if you are the parent or guardian of the user and wish to notify us that a user is under the Minimum Age, please contact us as set out in Section 8 (Contact) below.
This section provides more detail on the types of personal information we collect from you, and why.
It also identifies the legal basis under which we process your data to the extent required by the data protection laws in your jurisdiction. To the extent the laws in your jurisdiction do not recognize the legal basis of performance of a contract or legitimate interest, you consent to the processing of your personal information for that purpose by consenting to the processing in this Privacy Policy.
Personal Information | Use | Legal Basis (where applicable) |
Information you provide to us (either directly or through a third party) | ||
Inputs and Outputs: such as user reference images (including photos), and other instructions provided in your creative sessions, the AI-generated content (such as images and others) generated in response and any other information that you provide to the Event. We also process any files that you may upload onto the Event. | We use this information to process your Inputs and provide you with Outputs in accordance with your instructions and to provide you with the Event. | Necessary to perform our contract with you to access the Event. |
Information generated as part of the Event | ||
Device information: such as device information, IP address, device specifications, and other device information. | We use this information to: · detect and identify errors and bugs, and troubleshoot; and · monitor and analyse instances where you encounter errors. · To confirm the eligibility to attend the Event | It is in our legitimate interests to maintain the functioning of our Event, diagnose errors and make sure only eligible users can attend the Event. |
Your personal information will be stored on servers in Singapore. We also have global support, engineering, and other teams who support the Event, including from Mainland China.
We will transfer data outside of the jurisdiction in which you are based for the purposes described in this Privacy Policy. When we do so, we will take steps to ensure that your personal information is protected and we implement safeguards where required safeguards include standard contractual clauses, adequacy decisions where available, data processing agreements with all third-party data processors, and other contractual safeguards.
We will share your personal information with third parties in the following situations:
· Third parties that provide services in support of the Event, including providers of services that process personal information identified in this policy in our legitimate interests of efficiently providing the Event. For example, we will transfer your personal information to third-party AI model providers that process your Inputs and provide you with Outputs which may include providers located outside of your jurisdiction, such as in Mainland China, United States, etc.
· Companies within our corporate group who process your personal information in our legitimate interests to efficiently provide the Event. All such group companies may only use your personal information in accordance with this Privacy Policy.
· Regulators, judicial authorities, and law enforcement agencies. There are circumstances in which we may be legally required to disclose personal information about you, such as to comply with legal obligations or processes. We may also disclose personal information to regulators, judicial authorities, and law enforcement agencies to ensure safety, security, or compliance with laws.
· Third parties to ensure safety, security, or compliance with laws. We may disclose your personal information to: (a) enforce our terms and conditions and other agreements, including investigation of any potential violation thereof; (b) detect, prevent, or otherwise address security, fraud, or technical issues; or (c) protect the rights, property, or safety of us, our users, a third party, or the public as required or permitted by law.
· Professional advisors. We may disclose your personal information to auditors, law firms, or accounting firms, as a matter of our legitimate interests to assess, protect, enforce and defend our rights and to comply with our legal and regulatory obligations.
· A third party that acquires all or substantially all of us or our business. We may also disclose your personal information to third parties if we either: (a) sell, transfer, merge, consolidate, or reorganize 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 personal 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.
We have information security and access policies regarding access to our systems and technology, and we protect personal information using appropriate technological protection measures such as encryption, hashing, role-based access controls, audit logs of data access.
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 via the internet; any transmission is at your own risk.
Please note that we do not keep your data for longer than is necessary to fulfill the relevant purpose described above unless we are required or permitted to do so under law. If we retain your personal information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.
Personal Information | Retention Policy |
Device information | Stored for the lifetime of the Event or until account deletion in accordance with your request – whichever comes earlier and then for no more than 30 days. |
Inputs and Outputs | Stored for the lifetime of the Event or until account deletion in accordance with your request or until your deletion of Inputs and Outputs– whichever comes earlier and then for no more than 30 days. |
We offer our users the following rights in respect of your personal information (which you may have a legal right to exercise depending on where you are). Some of these only apply in certain circumstances (we will let you know if that is the case when you request the exercise of the right). You can exercise some of these rights directly by accessing and updating the personal information in your account. Otherwise, please contact us using the details in Section 7 (Contact) below.
· Access. You may have the right to access personal information we hold about you, how we use it, and who we share it with.
· Portability. You may have the right to receive a copy of certain personal information we process about you.
· Correction. You may have the right to correct personal information we hold that is inaccurate.
· Erasure. You may be able to delete your account, or remove certain personal information, by logging into your Event account or requesting erasure from us.
· Restriction of Processing to Storage Only. You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances).
· Objection. You may have the right to object to our processing of your personal information in certain situations.
· Consent Withdrawal. To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us. 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 Event. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.
You also have the right to lodge a complaint directly with us, as well as with the relevant data protection authority in the country you live or work.
If you are a user wishing to submit a data subject request, please contact us by using the below contact information.
Please get in touch with us if you have any questions. You can reach us via Data Subject Rights (DSR) form you can reach here. This DSR Form also allows you to contact our Data Protection Officer with your privacy related questions or concerns;
If you are an agent or official of a regulatory authority and have a specific data and privacy regulatory inquiry, please use our Data and Privacy Regulatory Inquiry Form here.
We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.
We may provide links or access to third-party platforms, services and features as part of the Event. If you follow links to sites or platforms or enable features that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Our inclusion of such links or access to such features does not, by itself, imply any endorsement of the content on such platforms, the operation of such features, or of their owners or operators.
If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.
10. Our Representatives in Certain Jurisdictions
Jurisdiction | Representative | Address | Contact details |
EEA | Proxima Beta Europe B.V. | Buitenveldertselaan1-5,1082 VA, Amsterdam, the Netherlands | See Section 7 |
UK | Image Frame Investment (UK) Limited | Suite 1, 4th Floor 80 Strand, London, United Kingdom WC2R 0RL | See Section 7 |
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.