PRIVACY NOTICE – PUBG Partnership Program

PURPOSE OF THIS NOTICE

PUBG Corporation and our Affiliates. (collectively, “we”, “our”, “us”, “the Company”) keep and process information about you when you enroll, register or otherwise participate in the PUBG Partnership Program. This Privacy Notice describes how we collect and use personal information about you so that we can provide you with the services that you request, including the PUBG Partnership Program, improve your experience with us and communicate with you about our products, services and other matters during and after your relationship with us, in accordance with the EU General Data Protection Regulation ((EU) 2016/679) (GDPR).

It is important that you read this notice, together with any other notice we will provide on specific occasions when we are collecting or processing personal information about you, or providing you with other information about the PUBG Partnership Program so that you are aware of how we collect personal information, why we collect it, under what circumstances we will share it with third parties, and what your rights are under the GDPR.

If this notice changes in the future, we will post an updated version on our website and that updated version will then be the notice in effect.

DATA CONTROLLER AND CONTACT DETAILS

The Company is the data controller for the purposes of the GDPR and other applicable data protection laws. If you wish to contact the Company regarding your personal information or concerns you have about this Privacy Notice, please contact

[Contact Information]

[DPO contact information in case appointed]

DATA PROTECTION PRINCIPLES

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

The GDPR defines “personal data”, or “personal information”, as any information about an individual from which that person can be identified. We collect, store, and use certain categories of personal information about you, such as:

  • Personal contact details such as your name, surname, ID, postal address, phone number, product preferences and email addresses
  • Information collected online such as IP address, time stamps and system information
  • Other information required for registering or participating in the PUBG Partnership Program, including content platform, primary platform link, secondary content platform and link, game platform, in-game username, discord information, shirt size, hoodie size, personal website link, the location of your PUBG content, the largest content platform, reasons for you being a PUBG partner, channel name, channel URL, channel type (e.g., Twitch, YouTube, FacebookLive, Mixer, CubeTV), secondary channel URL, secondary channel type, country, region, language, Twitter link, Facebook link and Instagram link

HOW YOUR PERSONAL INFORMATION IS COLLECTED

We collect your information either directly from you (e.g., you registering on the PUBG Partnership Program website or you filling out a form) or from entertainment platform providers.

OUR USE OF COOKIES

We regularly use browser tracking cookies.  A cookie is a small text file that is placed on your hard disk by our website. Cookies are uniquely assigned to you, and can only be read by a website or web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer.

We use cookies in order to improve your experience. For example, we use cookies to:

  • Recognize you when you return to one of our websites
  • Study how our customers navigate through our website and which products they request in site searches
  • Customize the message and delivery of online banner ads based on your online behavior.

Through our use of cookies, we may also track and maintain the identity of the website you visited immediately prior to visiting our website. We do not otherwise track any information about your use of other websites.

Cookies are also used to review how visitors to our website navigate our site or interact with our email advertising. Third-party companies assist in the collection and analysis of this data. Your name, street address or credit card number is not accessed by or shared with other companies.

HOW WE RESPOND TO DO NOT TRACK SIGNALS

We may enable tracking technologies to collect personal information about your online activities over time and across different websites, including the PUBG Partnership Program site. We use this information to better understand your preferences and send you marketing and other promotional materials that may be of interest to you.

Your web browser may enable you to indicate your preference as to whether you wish to allow websites to collect personal information about your online activities over time and across different websites. At this time the PUBG Partnership Program site does not respond to the preferences you may have set in your web browser regarding the collection of such personal information, and our site may continue to collect personal information from you both while you browse and after you leave our website in the manner described in this Policy. We do not treat users differently if they have indicated that they do not wish to allow our websites to collect their personal information over time and across different websites.

We may enable third parties to collect personal information in connection with the PUBG Partnership Program site. As described above, we work with a variety of advertising and third-party companies that use tracking technologies on our websites in order to provide tailored advertisements on our behalf and on behalf of other advertisers on the internet. This notice does not apply to, and we are not responsible for, any collection of personal information by third parties on our sites.

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following purposes:

  • Providing products and services
  • Managing and administering our websites and programs, including the PUBG Partnership Program
  • Performing marketing campaigns or other promotional activities or events
  • Planning, performing and managing our relationship with you in connection with the PUBG Partnership Program
  • Ensuring compliance with legal obligations such as record keeping obligations
  • Solving disputes, enforce our contractual agreements and to establish, exercise or defend legal claims

We will use your personal information in the following legal bases:

  1. Where we need to perform the contract we have entered into with you.
  2. Where we need to comply with a legal obligation.
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We can also use your personal information in the following legal bases, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).

DATA SHARING

We share your data with third parties, including affiliates and third-party service providers, in or outside the EU to comply with our contractual requirements in connection with the PUBG Partnership Program.

If such a recipient is located outside of the European Union and the European Economic Area (“EEA”) in a country that is not recognized by the European Commission as ensuring an adequate level of data protection, we will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws. These measures include data transfer agreements implementing European Commission’s Standard Contractual Clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for personal information).

DATA SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, as more fully set out in our Data Retention Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. Broadly, most of your information is kept for the duration of our working relationship with you.

In certain circumstances we anonymize your personal information so that it can no longer be associated with you, in which case we will use such information without further notice to you.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction and/or deletion of the personal information.
  • Request the restriction of the processing of your personal information.
  • Request the object to that processing (especially if we use your information for direct marketing, you can “opt out” at any time)
  • Request receipt or transmission to another organization, in a machine-readable form, of the personal information that you have provided to us

We will need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

In the event that you wish to make a complaint about how we process your personal information, please contact pubg_privacy@bluehole.net and we will endeavor to deal with your request as soon as possible. You have also the right to complain directly to the relevant data protection authority.

LINKS TO OTHER SITES

Occasionally we provide links on our websites to other sites we think you will enjoy. These sites operate independently of us and have established their own privacy and security policies. For the best online experience, we strongly encourage you to review these policies at any site you visit. We are not responsible for the content or practices of any linked websites which are provided solely for the convenience and information of our visitors.

ENQURIES ABOUT THIS NOTICE

If you have any questions about this notice or how we handle your personal information, please contact pubg_privacy@bluehole.net.

YOUR CALIFORNIA PRIVACY RIGHTS / QUESTIONS OR COMMENTS

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy. As discussed above, if you want to opt-out of any sharing of your information please contact us at:

pubg_privacy@bluehole.net

6, 7, 8F 12, Seocho-daero 38-gil Seocho-gu, Seoul, the Republic of Korea

To find out information about any rights you may have under Civil Code section 1798.83, please contact us at the above address/telephone number/email address.

CHANGES TO THIS NOTICE  

We reserve the right to update this notice at any time without prior notice, and we will notify you when we make any material updates.

Last Revised:  November 1st, 2018