Naruto Online Privacy Policy

Last Updated: 10 September 2021

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we need to provide the Game?

If you register an account to use the Game then we will need some information from you to set this up. If you choose to set up your profile using a social media account, we also collect information, including contact details, gender and birth date, from that social media account. If you choose, you can provide certain other information to personalise the gaming experience and enable Game features. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns. More Information.

What information do we collect about you?

We collect information when you set up your account for the Game. If you choose to set up your Game profile using a social media account, we will collect your information from that social media account such as your Facebook ID and your Oasis user ID in order to set up your account. More Information

How will we use the information about you?

We use your information to provide the Game to you. We use your information to create and verify your account, allow you to manage your account and to support and improve the Game. We also use your information for account verification, security purposes and to support and improve the Game. We do not share your information with any third parties, except where we need to in order to provide the Game (e.g., use local cloud providers or to back up your data; use our affiliates around the world to help us to deliver the Game) or we are instructed to by a court, authority or compelled by law. More Information

Who do we share your information with?

We use some third parties for support services, such as game servers and support ticketing. When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us deliver the Game and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information

Where do we process your information?

Our servers are located in Germany, Singapore, United States and the Netherlands. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including the People’s Republic of China (for this purpose excludes Hong Kong SAR, Macau SAR and Taiwan) (“PRC”). More Information

How long do we keep hold of your information?

We generally retain your information for the Game for the period during which you maintain an account, after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws. We delete certain information earlier at your request, and in accordance with local law. More Information

How can I exercise my rights over my information?

Depending on where you are, you may have rights to access, receive copy of, or delete, your data or restrict or object to our processing of, your data. More Information

How to get in touch with us

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will notify you within the Game. More Information

Contact Information

Joint Data Controllers: Oasis Interactive Limited | Email: gdpr@oasgames.com

                     Proxima Beta Pte. Limited | Email: dpo_naruto@proximabeta.com  

EU Representative:

For Oasis Interactive Limited: IMI Entertainment GmbH | Email: gdpr@oasgames.com

For Proxima Beta Pte. Limited: Proxima Beta Europe B.V. | Email: dpo_naruto@proximabeta.com  

Turkey Representative:

For Proxima Beta Pte. Limited: Özdağıstanli Ekici Avukatlık Ortaklığı. Email: turkeydatarep_proximabeta@iptech-legal.com  

 

 


INTRODUCTION

This privacy policy explains the when, how and why when it comes the processing of your personal information in connection with the game titled Naruto Online (“Game”), and sets out your choices and rights in relation to that information. Please read it carefully - it is important for you to understand how this happens and how you may control it.

When you contract to use the Game, 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.

 

Oasis Interactive Limited (Oasis”) is a company registered in Hong Kong with its office located at Unit A1 of Unit A, 11th Floor, Success Commercial Building, 245-251 Hennessy Road, Hong Kong. Oasis can be contacted at gdpr@oasgames.com. The representative of Oasis in the EU for the purpose of EU data protection laws is IMI Entertainment GmbH, a company registered in Austria. Their registered address is Wiedner Hauptstrasse 51/2/15, A-1040, Vienna, Austria and can be contacted at gdpr@oasgames.com. Oasis’ data protection officer can be contacted at gdpr@oasgames.com.  

Proxima Beta Pte. Limited (“Proxima Beta”) is a company registered in Singapore with its office located at 10 Anson Road, #21-07 International Plaza, Singapore (079903). The representative of Proxima Beta in the EU for the purpose of EU data protection laws is Proxima Beta Europe B.V., a company registered in the Netherlands. Their registered address is Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands and can be contacted at dpo_naruto@proximabeta.com. Proxima Beta’s data protection officer can be contacted at dpo_naruto@proximabeta.com.

Oasis and Proxima Beta (collectively, “we” or “us”) are (except where otherwise stated in this policy) joint data controllers for the purpose of EU data protection laws. This means we jointly determine the means and purposes of processing personal data collected in connection with the operation of the Game.

If you have any comments, questions or complaints regarding the processing of your personal information, you should at first instance contact Oasis at: gdpr@oasgames.com. You can also contact Proxima Beta at any time at dpo_naruto@proximabeta.com.

SECTION 1: WHERE WE ARE A DATA CONTROLLER

The Types of Personal Information We Use

This section describes the different types of personal information we collect and how we collect it. The following is a high level summary of the types of personal information we use. 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 (including, if you log in via social media, your Facebook ID and your Oasis user ID in order to set up your profile); and

o   when you set up your profile for the Game (including information you voluntarily elect to provide in order to populate your profile).

·       Information we collect about you. We automatically collect certain data from you when you use the Game, including your IP address and device information (such as browser type and version information), information regarding your use of the Game, such as date and time stamps of actions, and transaction records if you make in-Game payments. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.

 

·       Information you generate and display in the course of using the Game. You may provide or generate information when you communicate with other users in the Game (e.g., chat log data, chat content).

Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Game. 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 web browser 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 is not intended for children, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction). By children, we mean users under the age of 16 years old; or in the case of users located in a country where the minimum age for processing personal data differs, the minimum age specified under law. For certain jurisdictions we have listed the minimum age in the table below.

Country in which the user is located

Minimum age of the user

Algeria

19

Australia

18

Bangladesh

18

Brazil

18

Cambodia

18

Egypt

18

European Economic Area/Switzerland

16

Hong Kong

18

Indonesia

21

Japan

20

Kingdom of Saudi Arabia

18

Kuwait

21

Macau

18

Malaysia

18

Mexico

18

Morocco

18

Myanmar

18

Philippines

18

Qatar

18

Serbia

15

Singapore

18

South Africa

18

Sri Lanka

18

Taiwan

20

Tunisia

18

Turkey

18

United Arab Emirates

21

United Kingdom

13

United States

16

Vietnam

16

 We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at gdpr@oasgames.com or dpo_naruto@proximabeta.com.

How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the United Kingdom, the European Economic Area, Switzerland, or Turkey (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

Personal Information

Use

Legal Basis for Processing (EU)

Game

Log-in information:

·       Oasis user ID

·       Facebook ID (if using Facebook login)

 

We use this information to:

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

·       store your Game data (including level and progress) with your profile.

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

Region Location (manually selected by you)

We use this information to determine your statutory rights under applicable data protection laws.

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

Game Data – Open ID, game play statistics (Level, Properties, 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.

Chat Data (Open ID, chat content (text, emoticons), time stamp) – users are able to enter free text and emoticons using the chat function.

We facilitate the posting of your communications with other users.

Necessary to perform our contract with you to provide the Game where you seek to use chat services.

Device Information (Browser type and version information)

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

·       for game analytics purposes.

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

Log Data (IP address, purchasing actions, game results (e.g., win or lose), in-game performance)

We use this information:

·       to maintain a record of log-in and actions of your account; and

·       for security and verification purposes.

Necessary to perform our contract with you to provide the Game and retain your record of progress.

Transaction Records: payment data (Open ID, Order ID, currency, payment amount in chosen currency, game coin, time, IP address, source channel ID, device type)

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

Necessary to perform our contract with you to provide the Game, information about your in-game purchase history and to restore purchases of in-game items.

Customer Support Ticket ID & User Communications with Support (User ID, ticket description, certain Log Data if necessary)

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.

How We Store and Share Your Personal Information                  

Pursuant to our contract with you to provide you with the Game, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers. Our servers are located in:

·       Germany;

·       Singapore; 

·       United States; and

·       Netherlands.

Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including the PRC. We share your personal information with selected third parties. Situations where this occur are:

·       third parties that provide services in support of the Game including:

o    providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Game; and

o   AWS, located in Japan, for the purpose of processing payments;

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

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

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 implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility any transmission of your information.

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

Log-in information

Region Location (manually selected by you)

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

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for 30 days.

Chat Data

We do not store this information. Your data is transferred through our game servers transiently to facilitate exchange of chat data between players.

Device Information

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for 30  days.

Log Data

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for 30 days.

Transaction Records

Stored for 1 year from transaction date. Upon receiving a request for account deletion, such data will be deleted within 30 days unless such data must be retained in order to comply with our legal obligations.

Customer Support Ticket ID & User Communications with Support

Stored for 30 days from your operation log. Upon receiving a request for account deletion, such data will be deleted within 30 days.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

Your Rights

Some jurisdictions’ laws grant specific rights to users of the Game, which are set out in this section.

This section (“Your Rights”) applies to users that are located in the Relevant Jurisdictions. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

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). To exercise any of your rights, please contact us at gdpr@oasgames.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. If you believe we hold any other personal information about you, please contact us at gdpr@oasgames.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 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 with certain exceptions. We will provide further information to you about this if you make such a request. 

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 we hold about you by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at gdpr@oasgames.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 contact us at gdpr@oasgames.com.

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 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.  

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 contacting us at gdpr@oasgames.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at gdpr@oasgames.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 are welcomed and should be addressed to Oasis at: gdpr@oasgames.com. You can also contact Proxima Beta at any time at dpo_naruto@proximabeta.com. In the event that you wish to make a complaint about how we process your personal information, please contact Oasis in the first instance at gdpr@oasgames.com and Oasis will endeavour to deal with your request as soon as possible. You can at any time contact Proxima Beta at dpo_naruto@proximabeta.com and Proxima Beta will endeavour to respond to your query. 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.

Language

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.


 

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Game, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Algeria

By using this Game, you give us your consent for the collection, storage, treatment, use, and transfer your personal information to a third party (local cloud providers to back up your data or our affiliates around the world to help us deliver the Game) located in Germany, Singapore, PRC, United States and the Netherlands (as described in the Privacy Policy) where it is manually and electronically treated.

Australia

Children

 

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

Transacting Anonymously

 

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Game. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Game, including social media integration and In-Game purchases.

 

Your rights

 

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone +61 1300 363 992 or email enquiries@oaic.gov.au).

 

Data transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Bangladesh

Agreement

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. By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Germany, Singapore, United States and the Netherlands.

Age Restriction

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

Brazil

In order to use the Game, 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 INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

 

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

 

We collect your personal information for the following purposes:

 

For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.

 

We disclose personal information to the following types of entities:

 

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

 

Rights under the CCPA

 

If you are a California resident, you have the right to:

 

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

 

How to Exercise Your Rights

 

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, regarding other data by contacting us at gdpr@oasgames.com or dpo_naruto@proximabeta.com.

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at gdpr@oasgames.com or dpo_naruto@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.

 

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

Egypt

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. If you do not consent to this Privacy Policy, you must not use the Game.

You are acknowledging your consent to the processing, storage, and cross-border transfer for your personal data. The cross border transfer may occur to any country in which we have databases or affiliates, in particular Germany, Singapore, the PRC, Netherlands and the United States.

If you are a new user, you have seven days to inform us of any objection you may have to the terms of this Privacy Policy before it becomes enforced. If you are a minor under 18 years of age, parental consent is required for us to provide you with the Game.

As an Egyptian data subject, you have the following rights under the Egyptian Personal Data Protection Law:

As the data controller, we hereby acknowledge that we will take all necessary technical and organizational measures, and apply the necessary standards to your protect personal data and its secrecy, and to protect it from being breached, hacked, damaged, or altered through an illegitimate act. We are obliged to protect and secure the processing of your data, the means and devices used for processing, and the personal data contained within. We acknowledge that the countries to which cross-border transfer of personal data may occur guarantee levels of protection of personal data that do not fall below that which is stipulated under the Egyptian Personal Data Protection Law.

 

Should we become aware of any breach or violation of your personal data, we hereby acknowledge our responsibility to inform the relevant authorities immediately. We acknowledge that we will inform you of the breach within three days of us informing the authorities, as dictated by Egyptian laws.

We will ask you to acknowledge any material changes to this Privacy Policy, for example through a pop-up notification in-app, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

France

Your Rights

 

Instructions for the processing of your personal data after your death

 

You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death.

 

The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent.

 

You may amend or revoke your instructions at any time.

 

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions, in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

 

When you wish to make such instructions, please contact us at gdpr@oasgames.com or dpo_naruto@proximabeta.com.

 

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

Indonesia

Consent

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

Data Subject Rights

You have the right to access your personal information stored in our Game from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the Game, we will notify you through the contact information provided by you or via the Game, to the extent required by local laws and regulations, at the latest 14 days since we acknowledge the breach of confidentiality.

Data Retention

Notwithstanding the provision on the erasure of personal information, to the extent required by local laws and regulations, we will retain your personal information, for a minimum of five years.

Notification to Amendment of this Privacy Policy

In the event we amend this Privacy Policy, we will provide a notification to you regarding the effective date of the changes at the latest fourteen (14) days prior to the effective date, through (i) a notice to be posted on the landing page of our website, pop-up notification, or the splash screen of our mobile app or (ii) the contact information you provided to us. If you fail to explicitly express your objection to the amended privacy policy within the above notification period, you will be considered as accepting the changes and agreed to the new privacy policy. However, you may stop using or accessing our Game by unsubscribing or ceasing your use of the Game at any time, if you cease to agree with the amended privacy policy.

Data Accuracy and Third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

Minimum Age

If you are under the age of 20, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Game.

Consent to transfer to third parties

By clicking “accept”, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Germany, Singapore, United States and the Netherlands.

 

Your Rights

 

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at gdpr@oasgames.com or dpo_naruto@proximabeta.com.

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, export and storage of your Personal Information as described in this Privacy Policy.

Kuwait

You represent that you are at least 21 years old, or 18 years old and have obtained parental/guardian consent and, therefore, legally capable of contracting under the applicable laws and regulations in Kuwait.

By accepting this Privacy Policy, you expressly state that you authorize us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Malaysia

Language of this Privacy Policy

In the event of any discrepancy or inconsistency between the English version and Bahasa Melayu version of this Privacy Policy, the English version shall prevail.

Parental and Guardian Consent

If you are under the age of 18, please do not use the Game.

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Game, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Rights of Data Subjects

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the Game to you.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Oasis Interactive Limited

Proxima Beta Pte. Limited

Mexico

 

Spanish version

 

This privacy policy is provided in Spanish for users located in Mexico. In case of dispute, the Spanish version of this privacy policy shall prevail.

 

Data transfer consent

 

In general, we do not require your consent to carry out the transfers detailed in section “How we store and share your personal information”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.

By using the Game and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section “Your Rights” below.

 

Age restrictions

 

You won’t be able to use the Game unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf).

Types of Personal Information We Use

For clarification purposes, in the section "The types of personal information we use” and section “How we use your personal information” you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations.

Purposes of Processing

Please, be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and to carry out the transfer of personal data detailed in section “How we store and share your personal information”.

 

Your rights

The sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data, included in Section “Your Rights” above also apply to users that are located in Mexico. 

You also have the right to revoke the consent that you have provided us to process your personal data.

To exercise any of your rights, contact us at gdpr@oasgames.com or dpo_naruto@proximabeta.com.

To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us at gdpr@oasgames.com or dpo_naruto@proximabeta.com.

Cookies

Through the use of cookies, we collect certain information related to your browsing and device, some of which may be considered personal data (detailed in the relevant sections above). You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, you should consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionalities of the Game may no longer be available to you. For more information about our use of cookies and how to disable them, please visit our Cookie policy.

Morocco

The protection of your privacy is an important principle for us. We collect information for purposes strictly necessary for the proper use of the Game.

 

By accepting these conditions of use, you explicitly accept that your personal data may be subject to processing by the Game.

 

Kindly note:

 

New Zealand

This section applies to users located in New Zealand:

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

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 account. If you believe we hold any other personal information about you, please contact us at gdpr@oasgames.com or dpo_naruto@proximabeta.com.

Correction

You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at gdpr@oasgames.com or dpo_naruto@proximabeta.com.

Children

If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

Your rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

Data transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Philippines

Minimum Age

You are at least 18 years of age to be able to use the Game.

Your Rights

You are entitled to the following rights:

 

Consent

By consenting to this Privacy Policy, you consent to us:

·       collecting and processing your personal information as described in the section How We Use Your Personal Information” above;

·       sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and

·       transferring or storing your personal information in destinations outside the Philippines as described in the section How We Store and Share Your Personal Information” above.

 

Qatar

If you are using the Game in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Serbia

Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.

·       Name: Karanovic & Partners o.a.d. Beograd

·       Address: Resavska 23, Belgrade, 11000, Serbia

·       Telephone Number: +381 11 3094 200

·       E-mail: local.representative@karanovicpartners.com

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, Germany, Singapore, United States and the Netherlands.

Access

You have the right to access your personal information, 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 account. If you believe we hold any other personal information about you, please contact us at gdpr@oasgames.com or dpo_naruto@proximabeta.com.

Correction

You have the right to correct any of your personal information that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at gdpr@oasgames.com or dpo_naruto@proximabeta.com.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at gdpr@oasgames.com or dpo_naruto@proximabeta.com.

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it on inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Taiwan

We do not knowingly collect or solicit personal information from anyone under the age of 7 or knowingly allow such persons to register on the Naruto Online platform. If you are under 7, please do not attempt to use or register for our Game or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using the Game. In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using the Game.

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 gdpr@oasgames.com or turkeydatarep_proximabeta@iptech-legal.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 the right to (and to the extent permitted under applicable laws and regulations):

·       learn whether or not your personal data has been processed;

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

·       learn the purpose of processing of your personal data and whether they have been used accordingly;

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

·       request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

·       request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

·       object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems, and

·       demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information, as described in the Privacy Policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

Vietnam

By accepting this Privacy Policy, you expressly agree and authorize us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.

 

We maintain international standards and security practices for data protection. When your personal information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.   

 

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.

 

Your personal information, if required to be disclosed to the law enforcement agencies, public authorities or other judicial bodies and organisations, it will disclosed upon receipt of written request from such organizations.

 

Your Rights

 

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.