(Microsoft platforms follow the Microsoft’s Privacy Policy)

This Privacy Policy applies to users outside of the Republic of Korea and it will explain how Nimble Neuron Corp. (“Nimble Neuron”) uses the personal data we collect from you when you use Eternal Return (“Game”).

1. DATA WE COLLECT
   • Nimble Neuron may collect the following data for your use of the Game. Failure to provide any one of the data listed below may result in your inability to use any one of Nimble Neuron’s Game:

(i) Information directly from you: Your personal identification information (name, email address, phone number, date of birth, country of residence, etc.), Steam™ account ID and nickname, region, and in-Game identification information such as user ID, and nickname. You may also need to provide certain personal data, such as Steam™ account ID and nickname for your use of Steam™ Community service (https://steamcommunity.com/). Nimble Neuron uses Zendesk, Inc. for its customer service. Please visit Zendesk’s privacy policy at https://www.zendesk.com/company/customers-partners/privacy-policy, Marblers Games’ privacy policy at http://marblersgames.com/privacy-policy/, and GeekNation’s privacy policy at https://geeknation.info/privacy-policy/.

(ii) Information collected automatically: IP address, internet service provider, country code, computer operating system, hardware information, application software, country, game language, chat log, and user’s Game statistics using Google Analytics™ service. Please visit Google’s privacy policy at https://policies.google.com/privacy.

(iii) Information collected from third parties: If the Game is distributed and payment is handled by Valve Corporation, its software distribution platform Steam™ may collect Steam™ ID, Profile Image, along with payment information from you. Please review the Steam™ Privacy Policy for more information: https://store.steampowered.com/privacy_agreement/.

• Joint controllership

(i) In Europe, North America and Oceania (“the Regions”) the Game will be published by Kakao Games Europe B.V. (“Kakao”), located in the Netherlands. Where we collect and process personal data from users located in the Regions, Nimble Neuron qualifies as joint controller together with Kakao. The collection and process of personal data will only relate to in-game data for the provision of the Game as set forth in this privacy notice.

(ii) As joint controllers, Kakao and Nimble Neuron will collect your personal in-game data so that we can:

• Deliver the Game to you.
• Identify your account and provide you with customer support.
• Answer your questions that you inquired through our customer support.
• Determine, defend and/or exercise our legal position and rights.

Nimble Neuron and Kakao have concluded a joint controller agreement with in accordance with the GDPR, in which we have made arrangements about our joint responsibilities with regards to the processing of your personal data for the purposes above.

Please review the Kakao Privacy Policy for more information on how Kakao (further) handles the collection and processing of personal data: https://account.playkakaogames.com/pp.

For more information about the collection and processing of your personal data or regarding the joint controllership and the arrangements made in this respect you may treat Nimble Neuron as your first point of contact, and contact us via the contact details set out at the end of this privacy policy. 

2. LEGAL GROUNDS

The legal ground used for our processing activities are:

1. The processing is necessary for the performance and execution of a contract with you;
2. The processing is necessary for compliance with legal obligations (including our obligations under applicable tax laws, our legal administration obligations, to cooperate with supervisory authorities);
3. The processing is necessary for our legitimate (business) interests.

If applicable laws require so, we will process your personal data upon your (explicit) consent. If any kind of processing is based on your consent, we hereby inform you that you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

3. HOW WE USE YOUR DATA

Nimble Neuron collects your data so that we can:

• Deliver the Game to you.
• Comply with our legal obligations, legally binding orders or requests.
• Identify your account and provide you with customer support.
• Answer your questions that you inquired through our customer support.
• Provide technical support such as bug fixes and patches, improve our Game service.
• Provide technical protection against usage of unauthorized programs or improper gameplay that could harm Game users.
• Track usage patterns and generate statistics, such as a leaderboard and usage, from service use.
• Send or distribute a prize related to an event/promotion. This information shall be deleted once such event/promotion is completed and the prize(s) is received by the winner(s).
• To determine, defend and/or exercise our legal position and rights.

4. HOW WE STORE YOUR DATA
   • Generally, your data will be stored until purpose of collecting such data is achieved. However, Nimble Neuron may still store your data if it is required under applicable regulation, law, this privacy policy, or any other related agreement made between you and Nimble Neuron. Nimble Neuron securely stores your data in accordance with appropriate technical measures. However, due to unforeseen circumstances, Nimble Neuron does not guarantee loss, misuse, or alternation of your data by third parties.
5. RETENTION PERIODS
   • We will not store or keep your personal data for a longer period than is necessary in light of the purposes for which we process them. Only where we are legally obliged to, or where this is necessary for defending our interests in the context of judicial proceedings, we will store the personal data for longer periods.
6. INTERNATIONAL TRANSFER
   • Your personal data may be transferred outside the European Union, your countries, or regions that you are located. If your personal data is transferred, we will take all reasonable steps and implement the necessary data transfer mechanisms, such as the Standard Contractual Clauses adopted and approved by the European Commission, to protect any personal data are treated securely in accordance with this Privacy Policy and relying on our Game’s hosting service, Amazon Web Services.
7. YOUR DATA PROTECTION RIGHTS
   • Nimble Neuron would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

– The right to access: You have the right to request Nimble Neuron for copies of your personal data. We may charge you a small fee for this service.

– The right to rectification: You have the right to request that Nimble Neuron correct any information you believe is inaccurate. You also have the right to request Nimble Neuron to complete the information you believe is incomplete.

– The right to erasure: You have the right to request that Nimble Neuron erase your personal data, under certain conditions.

– The right to restrict processing: You have the right to request that Nimble Neuron restrict the processing of your personal data, under certain conditions.

– The right to object to processing: You have the right to object to Nimble Neuron’s processing of your personal data, under certain conditions.

– The right to data portability: You have the right to request that Nimble Neuron transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months after the data on which we received the request. In this case you will, of course, be kept fully informed of our progress. If you would like to exercise any of these rights, please contact us at our email: eternalreturn@nimbleneuron.com.

8. COOKIES
   • Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.
   • Nimble Neuron uses cookies in a range of ways to improve your experience on our website, including:

– Keeping you signed in.

– Understanding how you use our website.

– Provide you with personalized preferences setting.

• There are a number of different types of cookies, however, our website uses:

– Functionality: Nimble Neuron may use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

– Advertising: Nimble Neuron may use these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Nimble Neuron may share limited aspects of this data with third parties for advertising purposes. Nimble Neuron may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

• You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

9. PRIVACY POLICIES OF OTHER WEBSITE
   • The Nimble Neuron website(s) contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.
10. CHANGES TO OUR PRIVACY POLICY
    • Nimble Neuron keeps its privacy policy under regular review and places any updates on this web page. You will be deemed to have accepted such updates by continuing to use Nimble Neuron’s service. This privacy policy was last updated on November 30, 2021.
11. YOUR PRIVACY RIGHTS
    • In certain regions, you have a right to report a complaint or if you have concerns about how we process your personal data. Please contact your local authority for more information.
12. DATA PROTECTION OFFICER
    • Nimble Neuron’s data protection officer is Beom Choi (contact: eternalreturn@nimbleneuron.com).
13. HOW TO CONTACT US
    • If you have any questions about Nimble Neuron’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please contact us at: eternalreturn@nimbleneuron.com.