PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE Privacy Policy

Last Updated: [ 18 April ]2019

SUMMARY

What information do we collect about you?

We collect various information when you set up your account for the Game and during your use of the Game, as set out in this Privacy Policy.  If you choose to set up your Game profile using a social media account, we also collect information from that social media account. If you choose, you can provide certain other information to personalise the gaming experience and enable Game features, or participate in Game services. More Information

How will we use the information about you?

We use your information to create your account and to provide the Game to you, and to provide any Game features that you enable or Game services that you participate in. We also use your information for account verification, security purposes and to support and improve the Game. More Information

Who do we share your information with?

We use third parties for support services, such as cloud services and support ticketing. We use these third parties services solely to process or store your information for the purposes described in this policy. Any third party (selected by us) with whom we share user data will provide the same or equal protection of user data as stated in this policy. We also share your information with our related group companies and as required by law. More Information

Where do we process your information?

Our servers are located in Germany, Singapore, Hong Kong, Canada, the United States and the People’s Republic of China (excluding Taiwan, Hong Kong and Macau). Our support, engineering and other teams are located in our offices around the world (including the United States and Hong Kong). More Information

How long do we keep hold of your information?

We retain your information for the duration for which you hold your Game account and then, depending on the type of data, delete such data in accordance with the retention policy set out in this Privacy Policy. More Information

How can I exercise my rights over my information?

You may have rights to access, receive copy of, delete, or correct, your data or restrict or object to our processing of, your data. More Information

Dispute Resolution

If you have any concerns or complaints, please contact us here.

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will post a notification of such change in the Game. More Information

Contact Information

Data Controller: Proxima Beta Pte. Limited Email: dpo@proximabeta.com

EU Representative: Tencent International Service Europe B.V. Email: eudataprotection@tencent.com


INTRODUCTION

This privacy policy informs you of your choices and our practices regarding any personal information you provide to us. Your use of the mobile game PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE (“Game”) and website for the Game (“Website”) involves the collection and use of your personal information. It is important for you to understand how this happens and how you may control it.

When you use the Game or use the Website (the “Game Services”), you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using and storing your personal information, as described in this policy.

 

You acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy, you must not use the Game Services. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.

 

Proxima Beta Pte. Limited (“Proxima Beta”, “we” or “us”) is a company registered in Singapore with its office located at 10 Anson Road #21-07 International Plaza, Singapore. Our representative in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V., a company registered in the Netherlands. Their registered address is 26.04 on the 26th floor of Amstelplein 54, 1096 BC Amsterdam, the Netherlands and can be contacted at eudataprotection@tencent.com. The data controller for the purpose of EU data protection laws is Proxima Beta Pte. Limited.

If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at dpo@proximabeta.com.

The Types of Personal Information We Use

This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:

·         Information you give us. You give us information about you:

o   when you register for the Game (your nominated nickname, and information we import from your connected social media account (WeChat, Facebook, QQ, VKontakte, Twitter) in order to set up your profile, including your name as it appears on your social media profile, your user ID and your profile picture);

o   when you set up your profile for the Game (including region location and information you voluntarily elect to provide in order to customise gameplay, such as gender);

o   when you log-in as a ‘guest’ in order to use the Game (your nickname);

o   when you participate in a survey in the Game (in which case we will process the information you provide to us as part of the survey, including country, age, gender, profession and email address);

o   when you participate in one of our sweepstakes events (including email address, Open ID, phone number, mailing address and country); and

o   when you register for an e-sports event (team name, your name, nationality, proof of residency, email address, phone number and character ID). If you qualify to attend in person the global final of an e-sports event, we will also ask you for your passport and/or proof of residency information.

·         Information we collect about you. We automatically collect certain data from you when you use the Game and/or the Website, namely your IP address and device information (such as application version, battery level, WiFi strength, available space, network type, OS version, platform, carrier, country code, series ID, Android ID, MAC and IDFV) and information regarding your use of the Game and/or the Website, such as date and time stamps of actions. We also collect and store your data:

o   each time you interact with us, for example, when you use in-app support to communicate with us;

o   if you choose to log in using a social media service, we import the social media user ID and name of the friends (and in the case of Facebook, their Facebook nickname and profile picture) from your social media profile so that you can connect with your friends;

o   if you click on a link that advertises the Game, we store the Advertising ID for that advertisement with your profile;

o   if you enable chat services (audio and/or text) then we will process such data in order to deliver your messages to other users;

o   if you conduct any transactions within the Game, we collect information to facilitate your transaction and to maintain transaction records (Open ID, cost, product purchased, IP Address details of transactions linked to player ID, and device details including OS version, phone model, device root status);

o   if you contact our support team, we collect information including name (optional), Open ID, device ID, application version, battery level, WiFi strength, free space on device, network type, OS version, browser type, platform, carrier, country code, details of ticket, email address (optional if in-app support) and any information that you provide in your communications. You also have the option of providing a photo to illustrate any errors; and

o   when you are using the Game Services our security feature collects (in addition to the categories of data listed above) device information including the IMEI number and available memory; information about your internet connection including if applicable the wifi name and MAC address of the wifi access point; and a list of installed APK and running apps.

·         Information you generate and display in the course of using the Game Services. You may provide additional information as part of your profile (such as gender). You may also provide or generate information when you communicate with other users in the Game (chat log data and chat content, both audio and text). We generate an Open ID and use this to store your Game data, and we collect and store your Game play statistics in order to provide you with feedback and information about your Game play and progress. If you participate in a sharing event, we will process your Game data (prop types, wins, ranking and Game play statistics) to prepare a report for you. If you enable push notifications, we collect your Android device token or iOS device token, custom alias name, and IP address.

Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Game Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the Game) or web browser (in the case of the Website) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed.

For more information about our Cookies policy, click here.

Children

Our Game Services are not intended for children. Children must not use the Game Services for any purpose. By children, we mean users under the age of 13 years old; or in the case of users located in a country listed in the table below, the relevant age listed for that country.

Country in which the user is located

Minimum age of the user

Brazil

18

European Economic Area/Switzerland

16 (subject to the below)

Russia

14

Turkey

18

 

In the case of users located in the European Economic Area and Switzerland, persons under the age of 16 may use the Game Services if parental/guardian consent is obtained prior to using the Game.

If you believe that we have collected information from a child under the age of 13 years old, please contact us and we will delete the information.

How We Use Your Personal Information

We will use the information in the following ways and in accordance with the following legal bases:

Personal Information

Use

Legal Basis for Processing (EU)

Game

Nickname

We use this information to create your account for the Game in accordance with your request.

Necessary to perform our contract with you to provide the Game.

Social Connect Information (if you choose to log in via your social media account with these networks):

·         WeChat: Open ID, profile photo, alias, gender, region

·         Facebook: Name, Facebook ID, profile picture

·         VKontakte: userID, nickname, first name, last name, profile picture

·         QQ: Open ID, profile picture, alias, gender, region

·         Twitter: userID, nickname, profile image

We use this information to:

·         create your account for the Game in accordance with your request; and

·         share in-game photos on WeChat, Facebook, QQ and Twitter at your request.

Necessary to perform our contract with you to provide the Game.

Gender (if you elect to provide this information)

We only receive this information if you voluntarily provide it (other than users who log in via their QQ or WeChat social media account, when gender is also collected – please see above). It is used in order to customise gameplay.

Necessary to perform our contract with you to provide the Game with gender-specific content in accordance with your request.

Region Location (manually selected by you)

We use this information to:

·         set up your gameplay on a regional server;

·         provide you with your geographic ranking; and

·         improve gameplay.

Necessary to perform our contract with you to provide the Game.

Generated Open ID

We generate this and use this to store your Game data (including level and progress) with your profile, and it allows you to connect to the Game server.

Necessary to perform our contract with you to provide the Game.

Game Play Statistics (Level, Score/s)

We use this information to provide you with feedback and information about your gameplay and progress.

Necessary to perform our contract with you to provide the Game.

IP Address

We use this information to allow you to connect to the Game server.

Necessary to perform our contract with you to provide the Game.

Device ID, Device Information (application version, battery level, WiFi strength, available space, network type, OS version, platform, carrier, country code, series ID, Android ID, MAC, IDFV)

We use this information:

·         to improve our services, including the functionality of the Game;

·         for security and verification purposes;

·         identify and address bugs and assess game function for optimisation; and

·         to combat users registering for multiple accounts.

It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.

Friends List (WeChat, Facebook, QQ, VKontakte, Twitter)

If you choose to log-in using a social media service, we import the social media user ID and name of the friends from your social media profile so that you can connect with your friends.

If you choose to log-in through Facebook, and connect with your friends that also have the Game, we will import the Facebook nickname and profile picture of those friends.

Necessary to perform our contract with you to provide the Game and connect you with your friends.

Friends List (manually added by you)

We use this information so that you can connect with your friends.

Necessary to perform our contract with you to provide the Game and connect you with your friends.

Advertising ID

If you click on a link that advertises the Game, we store the Advertising ID for that advertisement with your profile.

It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.

Chat Data and chat log data

If you enable chat services (audio and/or text) then we will process such data in order to deliver your messages to other users.

Necessary to perform our contract with you to provide the chat services in-Game.

Transaction Records: payments on Google Play or iOS App Store (Open ID, cost, product purchased, IP Address details of transactions linked to player ID, and device details including OS version, phone model, device root status).

We use this information to facilitate your payment and maintain a record of your transaction history.

Necessary to perform our contract with you to facilitate your payment and provide you with details of your transactions.

Customer Support Ticket ID & User Communications with Support: Name (optional), Open ID, device ID, application version, battery level, WiFi strength, free space on device, network type, OS version, browser type, platform, carrier, country code, details of ticket, email address (optional if in-app support) and any information that you provide in communications with our support team. You also have the option of providing a photo to illustrate any errors.

We use this information to:

·         improve our services;

·         provide troubleshooting, such as addressing and remediating technical issues and bugs.

Necessary to perform our contract with you to provide and support the Game.

Security-Related Information: list of hack or cheating software, in-game screen information, device operation system settings, device information including mobile phone brand, model, CPU structure, CPU model, kernel version, resolution, application package of hack software; IMEI number and available memory; information about your internet connection including if applicable the wifi name and MAC address of the wifi access point; and a list of installed APK and running apps.

We use this information:

·         for security and verification purposes, including to detect cheating behaviours;

·         identify and address bugs and assess game function for optimisation;

·         solve game crashes and optimise compatibility of devices with the game; and

·         to combat users registering for multiple accounts.

It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.

Security-related information when transactions are conducted: whether certain billing security features of the Android SDK (security development kit) are installed on the device, and if so the version information.

We use this information when transactions are conducted on your account in order to detect fraudulent payment activity.

It is in our legitimate interest to ensure the security of transactions within our services.

Survey Information: Country, Age, Gender, Profession, Email and content of survey responses.

If you agree to participate in a survey conducted by us, we use this information to improve our services.

We collect this information with your consent.

Sweepstakes Participation Information: email address, Open ID, phone number, mailing address and country.

If you participate in a sweepstakes event, we use this information to send you your prize if you win.

We collect this information with your consent.

E-sports Event Registration Information:

·         team name, your name, nationality, proof of residency, email address, phone number and character ID.

·         if you qualify to attend in person the global final of an e-sports event, we will also ask you for your passport information and/or proof of residency.

If you register for an e-sports event, we use this information to create a team for you in the tournament, to organise the tournament and to communicate with the team.

We use the passport/residency information of players who qualify to attend the global final of an e-sports event to verify that you are located within a country in your nominated Game region and to assist with travel arrangements.

We collect this information with your consent.

Sharing Event Report Information: Game data (prop types, wins, ranking and Game play statistics).

If you participate in a sharing event, we use this information to prepare a report for you.

We collect this information with your consent.

Push Notification-related Information: Android device token, iOS device token, custom alias name, and IP address.

If you enable push notifications, we use this information to send you notifications.

Necessary to perform our contract with you to send you notifications about the Game.

How We Store and Share Your Personal Information                                     

In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers (depending upon your location and the game server you select). Our servers are located in:

·         Germany;

·         Singapore;

·         Canada

·         the United States;

·         Hong Kong; and

·         the People’s Republic of China (“PRC”) (excluding Taiwan, Hong Kong and Macau).

Please note that when your personal information is transferred outside your jurisdiction of residence, it will be subject to the laws of the country in which it is situated.

We share your personal information with selected third parties in and outside your country only to the extent allowed by applicable law, including:

·         third parties that improve the app or provide services in support of the Game and the Website, including:

o   for the purpose of processing customer support ticket ID and support communications;

o   providers of cloud services for certain functions, including sharing of in-game photos on Facebook, QQ and Twitter; and

o   for the purpose of arranging e-sports events;

·         related group companies with whom we share your personal information to operate the Game Services;

o   comply with a legal obligation, process or request;

o   enforce our terms of service and other agreements, policies, and standards, 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 (including exchanging information with other companies and organisations for the purposes of fraud protection); and

Any third party (selected by us) with whom we share user data will provide the same or equal protection of user data as stated in this policy.

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. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organisational controls and our policies and procedures (including this Privacy Policy).

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.

Data Retention

We will retain your personal information as described below (except if otherwise required to be retained by applicable law).

Personal Information

Retention Policy

Game

Nickname

 

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 15 days.

Social Connect Information:

·         WeChat

·         QQ

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request or you revoke access to your social media account) and then deleted within 60 days or as otherwise required by law.

Social Connect Information:

·         VKontakte

·         Twitter

·         Facebook

 

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Gender

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Region Location (manually selected by you)

Game Play Statistics (Level, Heroes, Score/s)

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Chat Communications (Audio message)

Stored for 7 days on our servers and deleted automatically upon expiry of such period.

Chat Communications (Text)

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 7 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Open ID

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

IP Address

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Device ID, Device Information

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 30 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Friends List (WeChat, Facebook, QQ, VKontakte, Twitter)

 

Stored for the duration of each session on the Game and deleted within 1 hour after you log out.

Friends List (manually added by you)

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Advertising ID

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Transaction Records

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for the duration of any retention periods for which such data must be retained in order to comply with our legal obligations.

Customer Support Ticket ID & User Communications with Support

Support data is deleted within 30 days of a lawful request from you for the erasure of such data (see the Erasure section of this privacy policy).

Security-Related Information

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 30 days.

Survey Information

Stored for: (a) if you provide your email as part of the survey, up to 6 months (in order for us to follow up with you) and then the data is anonymised; or (b) if you do not provide your email as part of the survey, up to 1 month and then the data is anonymised.

Sweepstakes Participation Information

Stored for the duration of the sweepstakes event and then deleted within 10 days.

E-sports Event Registration Information.

 

Stored for up to 3 months from the conclusion of the tournament.

Sharing Event Report Information

Stored for the duration of the event and then deleted within 10 days.

Push Notification-related Information

Stored for 90 days, or until account deletion in accordance with your request (whichever is earlier), upon which it will be deleted within 30 days.

 

Personal Information is kept until the end of its life cycle (as set out in the retention policy above). When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws.

Your Rights

This section (“Your Rights”) applies to users that are located in the European Economic Area only.

The sections titled “Access”, “Correction”, and “Erasure” also apply to users that are located in Brazil, Canada and India.

You have certain rights in relation to the personal information we hold about you. 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 email us at dpo@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 Game account and by contacting ue@proximabeta.com. If you believe we hold any other personal information about you, please email us at dpo@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., certain survey information) or pursuant to our contract with you (e.g., game play statistics), as described 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. 

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 (e.g., 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 personal information held about you that is inaccurate. You can access the personal information you have made available as part of your account by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please email us at dpo@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 email us at dpo@proximabeta.com.

You may request that we erase the personal information we hold about you in the following circumstances:

·         you believe that it is no longer necessary for us to hold such personal information; or

·         you believe the personal information we hold about you is being unlawfully processed by us.

You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., 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 Services 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 (e.g., 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.  

You may request we stop processing and just store the personal information we hold about you where:

·         you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;

·         you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead; or 

·         you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims. 

Objection

You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by emailing us at dpo@proximabeta.com

Announcements

We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Game access 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.  

Contact & Complaints

Questions, comments and requests regarding this policy, including our policies and practices related to the use of service providers outside your jurisdiction of residence, are welcomed and should be addressed to dpo@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@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.

Changes

If we make any material changes to this policy, we will post the updated policy here and notify our users within the Game. Please check this page frequently to see any updates or changes to this policy.

 


SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

If you are a user located in one the following countries, the terms set out below that apply in your country apply to you.

Brazil

In order to use the Game Services, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

 

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL DATA, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

Canada

Service providers

 

If a user located in the province of Alberta, Canada, wishes to obtain written information about our policies and practices with respect to service providers, they may contact us at dpo@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.

Russia

If you are using the Game in Russia, you consent (for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations) to the processing in accordance with this policy of your information. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Hong Kong, the United States and the People’s Republic of China (excluding Taiwan, Hong Kong and Macau).

The Data Controller, Proxima Beta Pte Limited, is the Person Responsible for Data Processing. To exercise any applicable rights, please email: dpo@proximabeta.com.

Turkey

Our Data Controller Representative in Turkey for the purpose of compliance with Turkish Law on Personal Data Protection Law and its secondary regulations can be contacted at dpo@proximabeta.com. Please include the word “Turkey” in the subject line of your email.

You have legal rights in relation to the personal information data we hold about you. As a Turkish data subject, you may have right to (and to the extent permitted under applicable laws and regulations):

a) learn whether or not your personal data has been processed;

b) request information about processing if your personal data has been processed;

c) learn the purpose of processing of your personal data;

d) know the third parties in the country or abroad to whom personal data has been transferred;

e) request rectification in the event personal data is incomplete or inaccurate;

f) request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the Personal Data Protection Law (Turkey);

g) object to certain processing of data, and seek certain remedies in accordance with the Personal Data Protection Law (Turkey).