Nitro X Privacy Policy


Nitro X Co., Ltd. (hereinafter referred to as the 'Company') values users' personal information and, to protect their rights, complies with the provisions of the 「Personal Information Protection Act」 and related laws and regulations, lawfully processing and securely managing personal information. Accordingly, pursuant to Article 30 of the 「Personal Information Protection Act」, this Privacy Policy provides comprehensive information on personal information processing, including the status of personal information processing such as collection, use, provision, and destruction of personal information, matters concerning measures to protect users' personal information, and methods for users to exercise their rights. This Privacy Policy applies to the games and all related services provided by the Company.


Article 1. Purpose of Processing Personal Information

1. The Company processes personal information for the following purposes. Personal information being processed will not be used for purposes other than the following, and if the purpose of use is changed, necessary measures such as obtaining separate consent in accordance with Article 18 of the 「Personal Information Protection Act」 will be implemented.
① Securing smooth communication channels for delivering notices, handling complaints, etc.
② Providing customer services such as handling inquiries regarding the use of paid information, resolving contract fulfillment disputes, and processing payment refunds.
③ Supporting in-game play and community services.
④ Marketing and advertising purposes
- Providing information on new service events
- News about game services such as new game releases and updates
- Providing information on various promotions and events using the Company's own channels
- Improving service quality and processing statistical information
- Securing accurate delivery addresses for prizes, etc.
⑤ Providing other content and authentication services


Article 2. Period of Processing and Retention of Personal Information

1. The Company processes and retains personal information within the period of retention and use of personal information agreed to by the user at the time of collection, or within the period of retention and use of personal information stipulated by law.
① User management, service use: Retained for 90 days (3 months) after withdrawal request (to resolve consumer complaints, disputes, and prevent unwanted withdrawals due to personal information theft upon game withdrawal).
② Event processing: Retained for up to 3 months after event reward distribution is completed.
③ Retention of personal information according to relevant laws and regulations
- Act on Consumer Protection in Electronic Commerce, etc.
1) Records on display/advertisement: 6 months
2) Records on contracts or withdrawal of offers, etc.: 5 years
3) Records on payment and supply of goods, etc.: 5 years
4) Records on consumer complaints or dispute resolution: 3 years
- Protection of Communications Secrets Act
1) Records on website visits: 3 months
2) Records on payment and supply of goods, etc.: 5 years
3) Records on consumer complaints or dispute resolution: 3 years


Article 3. Items of Personal Information Processed

1. The Company processes the following items of personal information.
① Membership Registration

Summon Hunter Idle


[Google] Google Member ID
[Apple] Apple Member ID

② Service Use
- User's mobile device information (model name, OS version, firmware version, device unique number, MAC Address, advertising identifier, IP Address, cookies, last access location, access date and time, service usage records, improper usage records)
③ Event Participation
- When participating in events/promotions: Name, User ID (member number), nickname, server information
- When winning events/promotions: Name, address, postal code, mobile phone number, (if taxes and public dues are incurred) unique identification number, copy of ID card
④ Cases where it is inevitably necessary for recovery or refunds during service use
- Email address, purchase history confirmation details, real name and family relationship verification documents to confirm payment by others


Article 4. Matters Concerning Provision of Personal Information to Third Parties

1. The Company processes the user's personal information only within the scope specified in the purpose of processing personal information, and provides personal information to third parties only in cases falling under Articles 17 and 18 of the 「Personal Information Protection Act」, such as user consent or special provisions of the law, and does not provide the user's personal information to third parties otherwise.
2. To provide smooth services, the Company obtains the user's consent in the following cases and provides only the minimum necessary scope.


Article 5. Matters Concerning Entrustment of Personal Information Processing Tasks

1. For smooth personal information processing, the Company entrusts personal information processing tasks as follows.

Entrusted Party (Trustee)


Entrusted Tasks


Nitro X Co., Ltd.


Customer consultation, service operation, and event winner notification


Product supply and delivery companies
(separately notified during events)


Supply and shipment of prizes for all game events

2. When concluding an entrustment contract, the Company specifies matters concerning responsibilities such as prohibition of personal information processing for purposes other than performing entrusted tasks, technical and managerial protection measures, restrictions on re-entrustment, management and supervision of the trustee, and compensation for damages in documents such as contracts, in accordance with Article 26 of the 「Personal Information Protection Act」, and manages and supervises whether the trustee processes personal information securely.
3. If the content of the entrusted tasks or the trustee changes, we will disclose it without delay through this Privacy Policy.


Article 6. Matters Concerning Cross-border Transfer of Personal Information

1. The Company entrusts game data storage to AWS (Amazon Web Services Inc.), an overseas corporation, as follows. AWS only performs physical management of the relevant servers and cannot access users' personal information.

Recipient


Amazon Web Services


Purpose of Transfer


Subscription and use of Summon Hunter Idle service


Country/Region


Korea


Date, Time, and Method of Transfer


Remote transmission using a dedicated network when using the service


Contact Information of Information Management Officer


aws-korea-privacy@amazon.com


Items of Personal Information Transferred


User unique key, service usage records


Period of Retention and Use of Personal Information


Consistent with the retention period stipulated in this Privacy Policy

Users can apply to refuse cross-border transfer through the relevant department. However, this service involves entrustment only when used in regions outside of South Korea, and transfer occurs for operational purposes when using global services. Therefore, if you refuse the transfer, you may not be able to use the service. Accordingly, if you refuse the transfer, your use of the service may be restricted.

2. The Company entrusts customer support services to Zendesk, Inc., an overseas corporation, as follows.

Recipient Company


Zendesk, Inc.


Purpose of Transfer


Storage of records related to handling user complaints or disputes


Country of Transfer


USA


Date, Time, and Method of Transfer


Transmission when using customer support services (when an inquiry is received)


Contact Information of Information Management Officer


privacy@zendesk.com


Items of Personal Information Transferred


User unique key, email address, inquiry content


Period of Retention and Use of Personal Information


Consistent with the retention period stipulated in this Privacy Policy

Users can apply to refuse cross-border transfer through the relevant department. However, as this service requires cross-border transfer for the use of the customer center consultation system, applying for refusal may restrict inquiry submission and consultation at the customer center.



Article 7. Matters Concerning Procedures and Methods for Destroying Personal Information

1. When personal information becomes unnecessary due to the expiration of the retention period, achievement of the processing purpose, etc., the Company destroys the relevant personal information without delay.
2. If personal information must be continuously preserved according to other laws and regulations despite the expiration of the retention period agreed to by the user or the achievement of the processing purpose, the relevant personal information is transferred to a separate database (DB) or stored in a different location for preservation. (Refer to 'Period of Processing and Retention of Personal Information')
3. The procedures and methods for destroying personal information are as follows.
① The Company destroys personal information recorded and stored in electronic file format in a way that the records cannot be reproduced, and personal information recorded and stored on paper documents is destroyed by shredding or incineration.


Article 8. Measures Concerning Destruction of Personal Information of Non-users

1. The Company may take necessary measures such as converting the information of users who have not used the service for 1 year into a dormant account and storing it separately or destroying it.
2. The Company notifies users who are scheduled for dormant account conversion of the fact that their information will be separately stored or destroyed, the expiration date, and the items of personal information to be separated or destroyed, 30 days prior to the dormant conversion, using methods available to notify the user (e.g., APP Push).
3. If you do not wish to have your account converted to a dormant account, you can log in to the service before the dormant account conversion.


Article 9. Matters Concerning Rights of Users and Legal Representatives and Methods of Exercising Them

1. Users may exercise their rights, such as requesting access, correction, deletion, or suspension of processing of their personal information, from the Company at any time.
*Requests for access, etc., to personal information of children under 14 years of age must be made directly by their legal representative. Users who are minors aged 14 or older may exercise their rights regarding their personal information themselves or through their legal representative.
2. To exercise your rights, please contact the Chief Privacy Officer in writing or by email (privacy@nitrox.games), and we will take action without delay. However, the Company may refuse a request for access or correction of all or part of the user's personal information if there is a justifiable reason, in which case the Company will notify the user of the refusal and explain the reason.
3. Requests for correction and deletion of personal information cannot be made if the personal information is specified as a collection target in other laws and regulations.


Article 10. Matters Concerning Measures to Ensure the Security of Personal Information

1. The Company takes the following measures to ensure the security of personal information.
① Administrative measures: Establishment and implementation of internal management plans, operation of a dedicated organization, regular employee training
② Technical measures: Management of access rights to personal information processing systems, installation of access control systems, encryption of personal information, installation and updating of security programs
③ Physical measures: Access control to computer rooms, data storage rooms, etc.
2. In addition to the matters stipulated by law, the Company implements the following activities to ensure the security of personal information.
① Personal information protection activities: Operation of a dedicated personal information protection organization, personal information protection training for personal information handlers
② Acquisition of domestic and international personal information protection certifications: ISO/IEC 27701, ISO/IEC 27001


Article 11. Matters Concerning the Installation and Operation of Devices for Automatic Collection of Personal Information and Refusal Thereof

1. The Company uses 'cookies' that store and frequently retrieve usage information to provide users with personalized services.
2. Cookies are small pieces of information that the server (http) used to operate the website sends to the user's computer browser and may be stored on the hard disk of the user's PC.
① How to install, operate, and refuse cookies
- Microsoft Edge : Top of web browser [...] icon > [Settings] > [Cookies and site permissions]
- Chrome : Top of web browser [...] icon > [Settings] > [Privacy and security] > [Cookies and other site data]
② Refusing to store cookies may cause difficulties in using personalized services.


Article 12. Matters Concerning the Chief Privacy Officer and Requests for Access to Personal Information

1. The Company designates a Chief Privacy Officer to oversee and take responsibility for tasks related to personal information processing, and to handle user complaints and provide remedies related to personal information processing.
2. Users can request access to their personal information in accordance with Article 35 of the 「Personal Information Protection Act」 from the department below. The Company will strive to process users' requests for access to personal information promptly.
① Chief Privacy Officer / Request for Access
- Name: Park Yong-jin
- Email: privacy@nitrox.games
3. Users can inquire with the Chief Privacy Officer about all personal information protection-related inquiries, complaint handling, damage relief, etc., that arise while using the Company's services. The Company will respond to and process user inquiries without delay.


Article 13. Methods of Remedy for Infringement of User Rights

1. To receive remedies for personal information infringement, users can apply for dispute resolution or consultation to the Personal Information Dispute Mediation Committee, the Korea Internet & Security Agency (KISA) Personal Information Infringement Report Center, etc. For other reports and consultations on personal information infringement, please contact the organizations below.
① Personal Information Dispute Mediation Committee: (No area code) 1833-6972 (www.kopico.go.kr/)
② KISA Personal Information Infringement Report Center: (No area code) 118 (https://privacy.kisa.or.kr/)
③ Supreme Prosecutors' Office: (No area code) 1301 (https://www.spo.go.kr/)
④ National Police Agency: (No area code) 182 (https://ecrm.cyber.go.kr/)
2. The Company guarantees users' right to self-determination of personal information and strives to provide consultation and remedies for personal information infringement. If you need to report or consult, please contact the department below.
① Customer Consultation and Reporting Related to Personal Information Protection
- Department: Service Support Office
- Email: privacy@nitrox.games


Article 14. Matters Concerning Changes to the Privacy Policy

1. This Privacy Policy will take effect on January 2, 2025.