Last update: January 3, 2019
WHO WE ARE
Kabam, Inc., is a world leader in game publishing, leading the way in global game culture, creating mobile games based on some of the world’s most iconic franchises, including Marvel and Transformers. We merge the science of game design with consumer behaviour to create immersive games with high-quality graphics.
Kabam, Inc., is incorporated in the United States and has affiliates in Canada and the United Kingdom (“Kabam”, “we” or “us”); each entity is a wholly owned subsidiary of Netmarble Corp, which is based in South Korea. Kabam’s games and related services are offered to global users and accessible via the iTunes App Store and Google Play, covering both iPhone and Android users.
Our goal at Kabam is to create the best gaming experience for our players in the industry by providing exceptional graphics and gameplay, personalized play experiences and hosted game forums that create a game community for the ultimate immersive experience.
To achieve these goals, Kabam collects and processes information about you. Your privacy is important to us and this Privacy Notice describes our privacy practices at Kabam with respect to the information and data collected from your use of our mobile applications and websites including mobile versions: (https://www.kabam.com, https://www.playcontestofchampions.com, https://www.forums.playcontestofchampions.com, https://www.transformersforgedtofight.com, https://www.forums.transformersforgedtofight.com and other websites controlled by Kabam that are related to our mobile applications) that provide online products and services (collectively referred to as “Services”). This Privacy Notice will help you understand what information we collect, how we use it and your choices related to our use of your information. Please review this Privacy Notice carefully together with our Terms of Service, available at https://playcontestofchampions.com/terms-of-service/, which sets out the contract between you and Kabam and govern your use of the Services. If you do not agree with this Privacy Notice, please do not use the Services.
INFORMATION WE COLLECT
We collect (a) personal data that you actively submit to us as a user, (b) personal data we automatically collect through your use of the Services, (c) non-personal data we automatically collect through your use of the Services, and (d) personal data received from third parties.
(a) Personal Data You Actively Submit to Us as a User
We collect your Player Name if you create one to access certain in-game features. We collect your email address at the time you create a Kabam ID Account. We collect your Apple Game Center ID and/or Google Play Gamer ID at the time you link an ID to your Kabam ID Account.
(b) Personal Data We Automatically Collect through Your Use of the Services
We collect online and mobile device identifiers when you access the Services, usually when you download and play one of our mobile applications or when you browse or interact with one of our websites. The type of identifier collected depends upon the device and technologies you are using to access the Services and include:
• IP address – Internet Protocol address used by computing devices such as personal computers, tablets and smartphones;
• MAC address – Media Access Control address assigned to a network interface controller;
• IDFA – Apple Device Advertising Identifier;
• GAID – Google Play/Android Device Advertising Identifier;
• GUID – Globally Unique Identifier, which is the reference used in relation to Microsoft technologies;
• UUID – Universally Unique Identifier, which is the reference used in relation to technologies other than Microsoft technologies.
The mobile device identifier IDFA is not collected if you have limited Ad Tracking on your device. Resetting your Ad Tracking setting will change collection of this data. Likewise, the mobile device identifier GAID is not collected if you have opted out of Ads Personalization on your device. Resetting your Ad Personalization setting will change collection of this data.
(c) Non-Personal Data We Automatically Collect through Your Use of the Services.
We collect non-personal device information, account information, and gameplay data automatically generated or collected through the Services including:
• General language & region setting (we don’t ask for or track precise location-based information from your device);
• Technical information such as app version, device type (hardware), OS or operating system (software) and OS type, browser and domain so we can serve you with the most relevant game content and optimize app performance for your device; and
• Game progress such as features used, in-game events, interaction with other players and purchases in order to maintain progress in your account and analyze aggregated game data to improve the game.
(d) Personal Data Received from Third Parties.
From time to time third-party advertising partners also provide us IDFA/GAID information from your device. This is to help us measure the effectiveness of our ad campaigns where we advertise our games on other third-party platforms and services. For example, when you click on an ad that directs you to install a Kabam game, we receive the IDFA/GAID to know the ad network and campaign source.
HOW WE USE COLLECTED INFORMATION
We collect, process, and use the information we collect for the following purposes:
• To provide you with access to the Services (including the social features of our games like in-game chat, messages, and alliances);
• To personalize your gameplay experience;
• To improve our games;
• To host related game web forums;
• To provide you personalized offers related to ‘purchase’ features of the game,
• To administer your account (including ensuring compliance with the Terms of Service);
• To provide you with technical support when requested;
• To notify you of new updates, features, enhancements, products and services,;
• To communicate with you about events, forums, game features, promotions and purchase opportunities;
• To notify you of changes to our Privacy Notice, Cookie Notice and/or Terms of Service; and
• As we, in our sole discretion, otherwise determine to be necessary to comply with applicable law or required to ensure the safety and/or integrity of our players, users, employees, third parties, members of the public, or Services.
We process your personal data as described above according to one or more of the following lawful bases, depending on each specific context and the types of personal information concerned:
• Processing as necessary to establish and fulfil a contract with you. For example, where you download and play our game that are subject to our Terms of Service and we provide our Services, administer your access to our Services, improve our games, analyze gameplay, communicate with you for transactional purposes, and provide customer support services;
• Processing in our legitimate interests (not superceded by your rights) for purposes that can be reasonably expected within the context of your use of our Services. For example, performing analytics to improve Services performance, monitoring in-game activities to prevent fraud, misuse of our Services and Terms of Service violations, and delivering in-game contextual advertising where applicable;
• Processing as necessary to comply with legal obligations. For example, maintaining accurate business records for tax and financial reporting or to respond to valid legal requests.
• Where we have your consent to use your personal information for marketing purposes.
HOW YOUR PERSONAL DATA IS SHARED
We share your personal data with the following types of recipients:
• Kabam affiliates in order to access the shared services available amongst the Kabam entities.
• Third-party service providers. We work with third-party service providers to support us in making the Services available to you. These are services like cloud hosting, analytics or other technical tools, and player support services. These service providers only process your data as directed by us for the purpose of supporting and servicing the Kabam games that you are playing. We do not sell your personal information to third parties.
• Competent law enforcement or regulatory authorities, government agencies, courts of law or other third parties. We may disclose your data or information about you in response to a request where we believe in good faith that we are under legal obligation, or legally permitted, to do so; or where we believe it is necessary:
• to detect, prevent, and address fraud, violations of our terms or policies, or other harmful or illegal activity;
• to protect ourselves such as establishing, exercising, or defending our legal rights (including our intellectual property rights and those of our licensors); or
• to protect your vital interests or those of any other persons such as public safety.
• Third parties in connection with a business transfer such as a merger or acquisition of any part of Kabam’s business, or a sale of all or a portion of Kabam’s assets to another company.
NOTICE REGARDING PUBLIC POSTING AREAS
Please be mindful that any information you include in a message you post to any public posting area is available to anyone with Internet access. PLEASE BE EXTREMELY CAREFUL WHEN YOU DISCLOSE ANY INFORMATION IN PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN THESE PUBLIC POSTING AREAS. For example, if you do not want people to know your email address, do not include it in any message you post publicly.
STORAGE OF YOUR PERSONAL DATA
We store information about website visitors and players on servers primarily located in the United States, and we may also store such information on servers and equipment in other countries. Where necessary, we utilize Standard Contractual Clauses approved by the European Commission to legitimize the transfer of personal information from the European Economic Area (“EEA”) or Switzerland to the United States and other countries.
We use technical and organizational measures to protect the personal data that we hold against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed. The practical reality is, however, no data transmissions over the Internet can be guaranteed to be 100% secure. Therefore, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a data breach that is likely to affect the security of your personal data, we may attempt to notify you electronically via email so that you can take appropriate protective steps and/or by posting a notice via the Services if a data breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
We retain your personal data for a reasonable period of time to fulfil the processing purposes outlined above. For example, your personal data, such as your Player Name and Email Address, are retained as part of your Kabam ID Account information as long as your Kabam ID Account is active so we can provide you with access to the Services. As another example, your personal data may be retained to fulfil our legitimate interests such as resolving disputes or enforcing our Terms of Service or other policies, or as necessitated by law or legal considerations, such as for tax, auditing, fraud detection, maintain marketing suppression lists of transactional history. When retention is necessary, we will de-identify such personal data to the extent reasonably possible. When retention is no longer needed to fulfil the processing purposes, your personal data is deleted from our records.
Depending on your residency, you may have certain rights that you may exercise in relation to your personal data, subject to applicable lawful exemptions. Where the EU General Data Protection Regulation (“GDPR”) applies, your rights consist of:
• The right to be informed;
• The right of access;
• The right to rectification;
• The right to erasure;
• The right to restrict processing;
• The right to data portability;
• The right to object; and
• The rights in relation to automated decision making and profiling.
You may also have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning personal data about you. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so. You may also contact us with your personal data inquiries or for assistance in modifying or updating your personal data and to exercise your rights. Our contact details are provided at the end of this Privacy Notice.
For marketing such as our communications with you about events, forums, games features, promotions and purchase opportunities, an ‘unsubscribe’ option is provided in the footer of every such communication. In addition, we may be contacted directly to unsubscribe. Our contact details are provided at the end of this Privacy Notice.
OUR POLICY CONCERNING CHILDREN
The Services are not intended for children under the age of 13, nor are they intended for children residing in the European Economic Area under the age of 16, and we do not knowingly collect any personal data from such children. Children under the age of 13, or 16 residing in the European Economic Area, should not use or attempt to use our Services. In the event we learn that we have in fact collected personal data from such a child, we will immediately delete this data.
THIRD PARTY WEBSITES
Our Services may contain links to other sites. We are not responsible for the privacy practices or content of other sites that are not controlled by Kabam. For information on how these sites use your personal data, please review their respective policies and contact them directly.
CHANGES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time. The “LAST UPDATED” legend at the top of this Privacy Notice indicates when this Privacy Notice was last revised. We will post a notice on our Services if we make any significant material changes. The revised Privacy Notice, when it takes effect, supersedes all previous Privacy Notices.
Inquiries may be made to:
575 Market Street, Suite 2450
San Francisco, CA 94105
Please put “Privacy Notice” in the subject line of the email and mark postal mail “Attention: Privacy” so that it may be directed to the correct person.