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 Authority – 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:

Personal data	Purposes
Payment and transaction data
Name; identification; date of birth; email; payment method; cardholder name, number, expiration date and verification code (CVV) of the credit or debit card	• Make transactions to purchase credits; • Implement anti-fraud methods for payment security; • Comply with legal and regulatory obligations.
Customer support
Name; nickname; email; general account data; generated content (messages, comments and images); questions; answers	• Provide a chat feature to help answer basic questions from players; • Use questions and answers to train artificial intelligence tools, without identifying the user/player.
Social networks, forums and Discord channels
Name; nickname; cell phone; country of residence; email; date of birth; general account data	• Integrate the account system with the forum account and activities associated with the main GnJoy account; • Integrate publicly available information on social networks.
Game data
Trading; party formations; quest completions; in-game partners and clans; items obtained or purchased; information that identifies the user in the backend (ISP, ASN, MACaddress, UUID, IMEI)	• Secure access to the game, authorize logins and process microtransactions; • Collect and monitor data for the safety of users/players; • Apply anti-cheat, anti-fraud and protection tools and methods; • Provide access to support, payment methods, forums and Discord; • Evaluate player complaints and apply sanctions if necessary; • Comply with legal regulations and local requirements; • Monitor and track gaming habits.

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. The Ministry of Justice classifies the game Ragnarök Online as not recommended for minors under 16 (sixteen) years of age. For users under 18 (eighteen), specific and highlighted consent given by a parent or legal guardian will be mandatory, in accordance with art. 14 of the 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 National Data Protection Authority (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:

Rights provided for in the LGPD	How you can exercise your rights
Confirm, access and correct	You can access the personal data processed and receive a copy of it, in most cases. You can also correct incomplete, incorrect or outdated personal data.
Request that personal data be made anonymous, blocked or deleted	If the personal data is unnecessary, excessive or processed unlawfully.
Request portability	Following the ANPD regulation, you may request that your personal data be transferred to another product or service provider.
Request deletion	Only for personal data processed based on consent, provided there is no legal justification for keeping it.
Know the consequences of consent	Be informed about the possibility of denying consent and its consequences.
Revoke consent	Expressly request the revocation of consent, free of charge and expeditiously, by sending an email to the DPO.
Learn about its shared use	Learn of which public and private entities your personal data has been shared with. In this Privacy Notice we inform you with whom we share your personal data. If you would like an updated list, please request it by email to the DPO.
Review decisions made automatically	Those made solely based on automated processing of personal data that affect your interests, such as decisions that define personal, professional, consumer and credit profiles or aspects of your personality.

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.

PERSON RESPONSIBLE FOR PROCESSING PERSONAL DATA

22. Our data controller is the Official DPO, a registered trademark of Vetaluti – Consultoria e Assessoria Ltda, legal entity under private law, registered on CNPJ under no. 37.781.826/0001-45 and/or LGPDfit Consultoria e Serviços Ltda, registered on CNPJ under no. 53.049.872/0001-00, which have as legal representative Mr. Tarcisio Teixeira and as technical manager Mrs. Ruth Maria Guerreiro da Fonseca Armelin.

INTERNATIONAL TRANSFER

23. 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.

24. 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

25. 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

26. 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

Cookies	Purpose	Duration
GNJOY_LATAM_USER_LOCALE	Handle multilingual rendering of each character displayed on the website	1 year
_ga	Google Analytics tracking tool used to identify unique website visitors and collect information about user interactions such as page views and clicks	2 years
_ga_<container-id>	Maintains session state in Google Analytics	2 years
authjs.callback-url	Process website navigation after completing the login process	Session
authjs.csrf-token	Prevents attacks where users can unintentionally manipulate requests during the login process	Session
next-auth.session-token-latam	Maintains and manages login authentication information. If the website is visited and kept open, the session time is extended to 30 minutes at regular intervals.	30 minutes
a_cookie_ck	Ensures that the cookie policy pop-up does not appear again after it has been acknowledged on the GnJoy website.	1 year
a_cookie_ck_ro	Ensures that the cookie policy pop-up does not appear again after it has been acknowledged on the GnJoy website.	1 year

Analytical/performance cookies

Cookies	Purpose	Duration
AMCV_ ; OptanonConsent ; __q_state_ ; _biz_flagsA ; _biz_nA ; _biz_pendingA ; _biz_uid ; _ga ; _ga_# ; _gcl_au ; _mkto_trk ; _uetvid ; cfz_amplitude ; cfz_facebook-pixel; cfz_google-analytics_v4 ; cfz_reddit ; kndctr_ ; mbox ; sparrow_id	Cookies provided by CloudFlare to maximize network resources, manage traffic, and protect the customer's website from harmful traffic	2 years
FPLC	Google Analytics Tool	20 hours
_gac_<wpid>	Google Analytics Tool	90 days
_gid	Google Analytics Tool	24 hours
_gat[_<customname>]	Google Analytics Tool	1 minute
__utma	Google Analytics Tool	2 years
__utmb	Google Analytics Tool	30 minutes
__utmc	Google Analytics Tool	Session
__utmt	Google Analytics Tool	10 minutes
__utmz	Google Analytics Tool	6 months
__utmv ; FPID	Google Analytics Tool	2 years
_dc_gtm_<property-id>	Google Analytics Tool, Tag Manager	1 minute
_gaexp	Google Analytics Tool, Optimize	User defined; maximum 93 days
_gaexp_rc	Google Analytics Tool, Optimize	10 seconds
_opt_awcid ; _opt_awmid ; _opt_awgid ; _opt_awkid ; _opt_utmc	Google Analytics Tool, Optimize	24 hours

Non-essential cookies

Targeting Cookies

Cookies	Purpose	Duration
DSID	Ensure that the user's ad personalization settings are properly respected	2 weeks
_gads	Show Google Ads	13 months
_gac_	Measure user activity and the performance of advertising campaigns	90 days
_gcl_	Help advertisers measure conversion rates	90 days
__gpi ; __gpi_optout	Google Ads Manager	13 months
NID	Google Ads	6 months
DSID	Google Ad Manager, Google Analytics, Display and Video 360, Search Ads 360	2 weeks
id	Google Ads Manager, Search Ads 360	24 months
GED_PLAYLIST_ACTIVITY	Google Ads Manager, YouTube	Session
ACLK_DATA	Google Ads Manager, YouTube	5 minutes
receive-cookie-deprecation	Display and Video 360	6 months
FPAU	Display and Video 360, Google Ads, Search Ads 360	90 days
ANID*	Display and Video 360, Google Ads, Search Ads 360	24 months
AID*	Display and Video 360, Google Ads, Search Ads 360	540 days
ar_debug	Display and Video 360, Google Ads, Google Analytics, Search Ads 360	90 days
IDE	Display and Video 360, Google Ads, Google Analytics, Search Ads 360	24 months
TAID*	Display and Video 360, Google Ads, Search Ads 360	14 days
FPGCLDC ; _gcl_dc ; _gcl_au	Display and Video 360, Google Ads, Search Ads 360	90 days
FLC	Display and Video 360, Search Ads 360	10 seconds
RUL	Display and Video 360, Google Ads	12 months
FPGCLAW ; FPGCLGB ; FPGSID ; _gcl_gb ; _gac_gb_<wpid> ; _gcl_aw ; GCL_AW_P ; _gcl_gs ; _gcl_ag ; Conversion	Google Ads	90 days
1P_JAR*	Google Ads	30 days
VISITOR_INFO1_LIVE ; VISITOR_INFO1_LIVE__k ; VISITOR_INFO1_LIVE__default	Google Ads, YouTube	180 days
APC	Display and Video 360	6 months
gclid	Google Ads	Session
_fbc	Managed by Meta to store the last visit	90 days
_fbp	Managed by Meta to store and track visits across websites	3 months
_ttp	Measure and improve the performance of advertising campaigns and personalize the user experience (including ads) on TikTok	13 months from last use
_pangle	Measure and improve the performance of advertising campaigns and personalize user advertising experiences provided by the Pangle network	13 months

INFORMATION ABOUT THIRD PARTY COOKIES

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

28. 28. 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

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

30. 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