Terms and Policies

1. Gravity Interactive Inc. and its affiliates operate in accordance with Law No. 13,709/18 – General Law on the Protection of Personal Data (“LGPD”).

2. In GnJoy games, personal data is collected to register accounts and enable access, support, forums, purchase of credits and other features. For the safety of players, anti-fraud methods are used to protect game payments, nicknames and passwords. These are some examples of activities involving personal data.

3. Access the full version of the Privacy Notice to find out more details about how personal data is processed, as well as the rights of data subjects.

4. Welcome! Gravity Interactive Inc. (“Gravity”, “GVI”, or “us/we”), headquartered at 7001 Village Dr, Buena Park, California, United States, 90621-2217, acts as controller of the personal data processed within the scope of this website and the games from GnJoy.

5. To provide transparency to data subjects, we have developed this Privacy Notice to inform people how personal data is processed, for what reasons, and how it is used and stored.

6. The Privacy Notice is supplemented by the Software End User License Agreement (EULA), Rules of Conduct, Account Policy and/or other documents made available on this website.

7. As this document may be changed at any time and without prior notice, we advise you to check the update date at the top of the page and re-read the Privacy Notice whenever you visit our website.

DEFINITIONS

8. The terms used in this Privacy Notice are defined by the LGPD and by the the Personal Data Protection and Privacy Glossary. To make it easier for you to read, we have summarized the main definitions:

• National Data Protection Agency – ANPD: Federal agency of a special nature responsible for overseeing, implementing and monitoring compliance with the LGPD, as well as for issuing complementary standards;
• Regulator: Party that makes essential decisions regarding the processing of personal data. Gravity acts as regulator of the personal data for players and other users who access, use and interact with this website and/or the game;
• Personal data: Information that identifies or may identify a natural person, such as name, email, cell phone, address, among others;
• Person in charge of processing personal data or DPO (Data Protection Officer):  Designated to function as a communication channel between the regulator, the data holders and the ANPD, in addition to other duties provided for in the LGPD;
• Security incident: A confirmed adverse event that compromises the confidentiality, integrity, availability and authenticity properties of personal data security;
• Operator: Party that processes personal data on behalf of and in accordance with the guidelines of the regulator;
• Data holder: Natural person to whom the personal data refers, such as players and users who access, use and interact with this website and/or the game;
• Processing:: Activities carried out using personal data, such as collecting, accessing, analyzing, transferring, storing, sharing, deleting, etc.

PROCESSED PERSONAL DATA AND PURPOSES

9. Gravity only processes personal data necessary to achieve its sought purposes.

10. The processing of personal data and its purposes will depend on how the data holder relates to Gravity, as described in the table below:

11. Personal data will be processed for the period necessary to achieve the intended purpose(s), considering the rights of the data subjects and the interests of the agents responsible for its processing (regulators and operators).

SHARING OF PERSONAL DATA

12. We may share personal data with the operators listed below, always respecting the LGPD, especially the Principle of Necessity, and in a manner compatible with the purpose(s) for which it was collected:

• Companies from the same economic group or affiliated with Gravity;
• Companies providing marketing, public relations, customer support and legal support services;
• Companies providing payment processing services, credit cards and financial institutions, with protective measures for the safe purchase of credits;
• Judicial, administrative, regulatory or governmental authorities, provided there is an express order.

13. In the case of sharing with operators, we will require that personal data be treated in accordance with our instructions, which include, but are not limited to, measures for secure storage, retention only for the necessary period and the impossibility of subsequent sharing with other organizations without prior and express authorization.

PERSONAL DATA OF MINORS

14.Each game made available on the GnJoy LATAM platform has its own age rating defined by the Ministry of Justice, which must be consulted before use. In the case of users under 18 (eighteen) years of age, specific and highlighted consent provided by one of the parents or legal guardian will be required, in accordance with Article 14 of the General Data Protection Law (LGPD).

15.Gravity encourages parents to guide their children to never share personal data online and to identify possible fraud committed by third parties.

THIRD PARTY WEBSITES

16. When accessing this website, you may see links to other websites or online services from third parties that are subject to their own privacy notices and rules of use. Gravity is not responsible for any damage or losses caused by third parties.

PROTECTION AND SAFETY MEASURES

17. Gravity adopts technical and administrative security measures to protect personal data from security incidents.

18. If any security incident involving personal data occurs that may entail risk or relevant damage to the data holder, Gravity will duly communicate this to the data holder and to the ANPD, in accordance with the LGPD.

RIGHTS OF DATA HOLDERS

19.For processing activities in which Gravity is the regulator, data holders may exercise the following rights in relation to their personal data:

20.To exercise these rights free of charge, or to ask questions about the LGPD or this Privacy Notice, please contact the DPO using the following email <atendimento@dpooficial.com.br>.

21.The data holder may also file a petition regarding their personal data against the regulator before ANPD by accessing the channel available at: https://www.gov.br/anpd/pt-br/canais_atendimento/cidadao-titular-de-dados/denuncia-peticao-de-titular.

INTERNATIONAL TRANSFER

22. Gravity may transfer personal data internationally to its affiliates in South Korea and/or the United States (California), which will also comply with applicable laws and responsibilities set forth in this Privacy Notice.

23.Personal data may be transferred internationally via official tools approved by Gravity, using VPN tools, access restriction and anonymization whenever possible, for the period necessary to achieve the following purposes:

• Analyze and resolve issues/bugs in the game, including but not limited to access issues, payment issues, anomalies or behavior in violation of the EULA or game rules that require specific analysis or support from the team;
• Share account data with the administrative team for legal evaluation and defense purposes;
• Monitor metrics regarding general gameplay, users, and information that is not user-specific (number of users logged into the game, for example);
• Share content related to events and player suggestions with the development team.

COOKIE STATEMENT

24.Cookies are files installed on users' electronic devices to collect information about the website for various purposes, such as to ensure the website's functionality, monitor performance or to display advertisements.

COOKIES USED

25.O site da Gravity utiliza cookies necessários, cuja desabilitação impede o funcionamento do site ou a utilização de serviços pelo usuário, assim como cookies não necessários, com funcionalidades não essenciais ao serviço, de modo que podem ser desabilitados pelo usuário sem prejuízo do funcionamento do site.

Essential cookies

Analytical/performance cookies

Non-essential cookies

Targeting Cookies

INFORMATION ABOUT THIRD PARTY COOKIES

26. Gravity has no control over how third-party cookies work, as they are created by another domain.

27. For more information and settings, the user can access the Privacy Policies/Notices of each third party to find out which cookies are used and how personal data is processed:

• Meta
• Google Analytics
• Youtube

HOW TO CONFIGURE COOKIES ON THE WEBSITE OR IN THE BROWSER

28.Cookies retain user data for the periods mentioned above, and may be transferred outside of Brazil.

29.The user has the option and can change permissions, block or refuse cookies at any time using the tools provided by the browser; however, it is possible that the usability of the website may be impaired. For more information, see the links below:

• Internet Explorer
• Firefox
• Safari
• Chrome
• Microsoft Edge
• Opera