PRIVACY POLICY

NDREAM Corporation (“company”, “we”, or “us”) is doing its best to protect the valuable personal information of our customers (“user”, or “users”) and complies with the relevant laws and regulations that information and communication service providers must comply with.

The company informs you of the purpose of using personal information collected from users through the privacy policy and what efforts and actions the company is taking to protect personal information.

The company's privacy policy can be changed from time to time due to changes in laws and guidelines related to personal information protection or changes in the company's internal policy. If the privacy policy is revised, we notify you of the changes, so users should check the changes from time to time through the website.

This privacy policy applies to mobile platform-based game services provided by the company and mobile game services in the PC environment (collectively, the “NDREAM Service").


Effective date: April 19, 2022

Article 1. Collection of Personal Information

“The company collects and uses only essential personal information necessary for providing users with the NDREAM Service.“

However, in order to provide better services, in addition to the “mandatory agreements”, users may be asked to check and consent to some “optional agreements” and provide additional information. Users who choose not to agree with the “optional agreements” can still use the basic services provided by the company without restriction.
The company collects the following personal information through users' membership registration, use of the NDREAM Service through external platform account linkage, participation in events or promotions, consultation with customer centers, and automatic collection of information.

1. Information Provided by the User
1) The information collected when using games through linking external platform (Google, Apple, or Facebook) accounts is as follows.
- [Required] User identification information (by platform), email address, nickname
※ When linking external platform accounts, we can receive information such as names, profile photos, and language configuration information, but we only collect and use user identification information and e-mail addresses for service linkage.
※ For user convenience, the company also provides some mobile platform-based game services in the PC environment. When using the service in a PC environment, no additional personal information is collected.

2) The information collected when signing up for membership through the company's platform is as follows.
- [Required] Email address, password

3) Additional information collected when using other services is as follows.
- Participation in events and promotions: membership number (ID), nickname, email address, mobile phone number, access IP address
- If you win a prize in events or promotions: membership number (ID), nickname, email address, mobile phone number
※ Depending on the event and promotion, the collected personal information may differ or additional personal information collection may be required. In such cases, we will obtain separate consent from the user.
- Participation in pre-order: email, mobile phone number, access IP address
- Inquiries/consultations at the customer center: membership number (ID), email address, nickname, membership number, server name, device information (device name, OS version), product name, payment number, and other information necessary for consultation
※ Depending on the type of inquiry, different personal information may be collected or additional personal information may be collected.
- Usage of the payment service: external platform (Google, Apple, or Facebook) user identification information, payment information (payment amount, payment date, etc.), email address
※ When users use payment services provided by Google or Apple, user identification information and payment-related information are neither collected nor processed directly by the company, according to the terms and conditions of the service of the two companies.


2. Automatically Collected Information
The following information can be automatically collected during the service usage.
- Game usage record (game progress and play data), access record, authentication record, fraudulent usage record, banning record, game version
- Mobile device information (mobile carrier information, device information, country information (MCC), and data from interaction with other users
- Data collected through cookies and similar technologies, and ADID, IFDA information (Users may reject to provide such information.)

Article 2. Purpose of Using Personal Information

"The company processes the personal information collected for the following purposes, and if any purpose changes, the user will be informed of the changes in detail before the company requests further consent."

1. Provision of the NDREAM Service and fulfillment of contract
1) Personal information is used for member management and identification.
2) Personal information is used for payment processing for paid services such as fee settlement, payment, and refund.
3) Personal information is used to handle user inquiries or complaints.
4) Personal information is used to improve user experience and game quality.
5) Personal information is used to deliver announcements on service failures, changes in terms and conditions, personal information usage details, etc.

2. Development and provision of services that are more suitable for users
1) Personal information is used to develop new services or to provide specialized services according to demographic characteristics.
2) Personal information is used to plan and provide various customized contents.
3) Personal information is used to provide additional services that are directly or indirectly related to the NDREAM Service.

3. Improvement of the NDREAM Service provision environment
1) Personal information is used to create an environment where services can be used comfortably and safely.
2) Personal information is used to check and fix various game errors or bugs.
3) Personal information is used to analyze the service usage environment and provide more suitable services in consideration of the user characteristics.
4) Personal information is used to prevent fraudulent subscriptions and restrict abusive usage.
5) Personal information is used to investigate illegal activities or to comply with relevant laws and regulations.

4. Delivery of advertisements or promotional information
1) Personal information is used to send notifications about promotions such as events.
2) Personal information is used for additional services and customized advertisements according to demographic characteristics.
3) Personal information is used for checking your intention to participate in an event or promotion, and for the delivery of prizes to participants and processing various taxes, etc.

Article 3. Provision of Personal Information

"The company shall not provide the collected personal information to an institution, organization, or partner ("third party") without the consent of the user."
However, the following cases are excluded.

1. When the user agrees in advance
If the company determines that it needs to provide the user's personal information to a third party, it will inform who provides the personal information and for what reason, and provide it after obtaining separate consent according to the consent procedure, and if the user disagrees, the company will not provide the personal information to a third party.

2. When necessary for the settlement of charges incurred by provided services

3. In the event of an investigative agency's request or a lawful obligation to provide personal information in accordance with the procedures and methods prescribed in the Act for the purpose of investigation

4. When the Company's affiliates, partners and service providers carry out services such as bill payment, execution of orders and dispute resolution (including disputes on payment or refund) for and on behalf of the Company

Article 4. Consignment of Personal Information Processing

Article 5. Overseas Transfer of Personal Information

Article 6. Duration of Retention and Use of Personal Information

“The company shall retain and use the user's personal information during the period agreed upon, and "destroy it without delay when the purpose of collecting and using personal information is achieved or the retention period expires."
(However, in order to minimize damage caused by unwanted membership withdrawal or payment theft due to internal settlement processing or personal information theft, information can be temporarily retained for up to 30 days after requesting membership withdrawal, and will be completely destroyed later.)

In addition, the following information shall be preserved for a certain period of time according to each stated reason and shall not be used for any purpose other than the stated purpose.

1. Reasons for holding information under relevant laws and regulations
1) Act on the Consumer Protection in Electronic Commerce, Etc.
- Records related to labeling/advertisement: 6 Months
- Records related to agreements or subscription withdrawal: 5 Years
- Records related to payments, supply of commodities: 5 Years
- Records related to consumer’s complaints or settlement of disputes: 3 Years

2) Protection of Communications Secrets Act
- Records on website visit: 3 Months

2. Reasons for holding information according to the company's internal policy
The company can store personal information collected for events or promotions for up to a year. However, the period may vary for each individual event or promotion, and the period informed through individual event or promotion, if any, will take precedence.

Article 7. Procedures and methods for destroying personal information

“The company destroys the user's personal information without delay after the purpose of collection and use is achieved or the period of retention and use has elapsed."

The procedure and method of destroying personal information are as follows.

1. Destruction Procedure
After the purpose of using personal information is achieved, it will be destroyed without delay according to the "6. Duration of Retention and Use of Personal Information".
※ However, even if the user deletes the mobile game app ("app"), the personal information collected by the company will not be destroyed immediately. If you no longer use the service provided by the company, please click “Withdraw from the game" in the settings menu of the app and apply for withdrawal.

2. Destruction Method
Hard copies are incinerated or shredded, and soft copies are permanently and irrecoverably deleted through technical methods

Article 8. Collecting Information from Minors

“The company does not collect information from minors under the age of 16 or under the equivalent minimum age prescribed by relevant laws and regulations. The company is fully aware that it has a special obligation to protect information about minors. The company's apps, websites, or applications prohibit minors from using services through consent to age restrictions from users, and the company does not intentionally collect minors' personal information."

1. Children in Europe
If the user is a child under the age of 16 in Europe, the service can only be used to the extent agreed by the parent or legal representative. Please consult with your parents or legal representative about this privacy policy so that the company can better understand how to use your personal information. The company is making reasonable efforts to verify the consent of your parents or legal representatives, and if the company has collected personal information from you without their consent, it will immediately delete it.

2. California minors
The company does not collect personal information about minors under the age of 16 living in California without clear approval, and for minors under the age of 13, it does not collect personal information without clear approval from parents or legal representatives. If you find out that you are a parent or legal representative and your child has provided us with personal information under these age restrictions, you can contact us using the contact information below and immediately request that your child's personal information and account be deleted.

Article 9. California Consumer Privacy Act

"The company complies with the California Consumer Privacy Act ("CCPA”).”

1. Collection and Sharing of Personal Information
The company may collect or share information that can directly or indirectly identify users, such as users or their devices, or information that can be reasonably connected to users.

- Identifier information: account information (ID), nickname, device information, email address, access IP, online identifier (cookie, advertisement ID, other similar tracking technology)
- Commercial information: purchased item (or product), payment and purchase-related records, purchase history, and purchase trend information

2. Purpose of collecting personal information
The above personal information is used/shared for the purpose of improving service quality, providing services, maintaining accounts, customer response services, identification, advertising, and user pattern analysis as follows.
- Solving technical problems and improving the company’s service quality
- User identification for providing the company’s services
- Preventing inappropriate gameplay that can negatively affect other users
- Customer support such as receiving and responding to customer inquiries
- Providing information and opportunities to participate in events and surveys
- Marketing and promotion
- User pattern tracking and trend analysis, and statistical analysis of service usage

3. Prohibition of personal information sale
The company does not sell and profit from the personal information of users who use the company's services.

4. No discrimination
The company does not discriminate against users who exercise their rights under the CCPA.

5. Guidance for California residents
1) Certain authorities may be granted if the user lives in California. The company is preparing preventive measures to protect users' personal information to comply with the California Consumer Privacy Act, and users have the right to request the following information.

- Source and collection purpose of personal information collected over the last 12 months
- Categories of personal information collected over the past 12 months
- Matters concerning the disclosure of personal information that occurred within the last 12 months
- Matters concerning the sale of personal information within the last 12 months
- Types of user rights specified in the CCPA and specific methods of exercising rights

2) Users have the right to request the deletion of personal information collected by the company.

3) The company does not track website visitors and does not use any signals for "Do Not Track". Therefore, the company does not monitor or take any action related to the "Do Not Track" signal or other mechanisms. For more information on "Do Not Track", please visit http://www.allaboutdnt.com.

Article 10. Your Right

"Users can view or correct their personal information at any time, and if users apply for withdrawal from membership or suspension of processing, the company takes necessary measures without delay."

1. The company can legally process personal information only if one or more of the following conditions apply.
1) When the user agrees with processing his/her personal information
2) When it is necessary to fulfill the contract concluded with the user or to provide services - Implementation of a contract with a user, settlement of charges, provision of services, etc. - Membership management, identification, etc.
3) When it is necessary to take related measures at the request of the user
4) When the company needs to process personal information to comply with legal obligations
- Compliance with relevant laws, legal procedures, government guidelines, or requirements, etc.
5) When personal information processing is necessary to protect the important interests of users (or other natural persons)
- Detecting, preventing, or responding, etc. to fraud, abuse, security risks, and technical problems that may cause damage to users (or other natural persons)
6) When personal information processing is necessary to perform business for the public interest or to exercise the company's public authority
7) When personal information processing is necessary for the legitimate interests pursued by the company or a third party

2. Users can exercise their rights in regard to each of the following subparagraphs to the company at any time.
Users have access to their personal information and have the right to correct inaccurate information. If you need additional details on your rights to exercise or wish to exercise your rights, please refer to our contact information at the bottom of this privacy policy. However, some of these rights may be linked to specific legal conditions and may not correspond with the specific situation of the user.

1) Right of access
Users have the right to confirm that they have access to personal information processed by the company. If you have any questions about personal information processing or want to know about the user's personal information processed by the company, please contact the company at any time to obtain the information.

2) Right to rectification
Users have the right to request the company to correct inaccurate personal information. In addition, users have the right to complete incomplete personal information by providing additional statements.

3) Right to be forgotten
Users have the right to request complete deletion of personal information and can request deletion from the company. The deletion of personal information can be done through the customer center (1:1 inquiry) or by selecting to leave the membership or delete the account on the in-game screen. However, if personal information is destroyed due to membership withdrawal, related information generated and accumulated while using the company's game service may be destroyed together.

4) Right to restrict the processing activities
Users have the right to restrict the company's personal information processing. However, if the user decides to restrict the company's personal information processing in relation to service provision, the user may not be able to use the service.

5) Right to data portability Users have the right to request the company to deliver their personal information in a structured, commonly used, and machine-readable form, and to request that such information be transmitted to other controllers.

6) Right to object Users have the right to refuse the company to process their personal information. However, if the user refuses the company's personal information processing, the use of the company's services may be restricted.

7) Right to lodge a complaint with a supervisory authority Users can contact the company at any time to resolve the issue if they are dissatisfied with the company's personal information processing method. In addition, users have the right to lodge a complaint with a supervisory authority at any time.

8) Right to withdraw consent If the company processes the user's personal information based on the user's consent, the user has the right to withdraw such consent at any time. The withdrawal of the user's consent will not affect the legitimacy of personal information processing based on the consent prior to withdrawal.

9) Right to automated individual decision-making, including profiling
The users may request to cease the automated treatment of personal information, including profiling, which has critical impact or cause legal effect on them.

If you wish to exercise the rights listed above, please contact privacy@ndream.com.

Article 11. Matters Concerning the Installation, Operation, and Refusal of an Automatic Personal Information Collection Device

1. The company uses “cookies" to provide customized services to users or to provide a more convenient website environment, and users may refuse this.

1) What Are Cookies?
Cookies are very small text files sent to the user's browser by the server used to run the website, and are stored on the user's computer hard drive. When a user uses the company's service, the server reads the contents of the cookies stored on the user's computer to check the user's information.

2) Purpose of Cookies
The company uses cookies to analyze the frequency of users' access to services, visit times, and number of visits, identify users' tastes and interests, and provide personalized services.

3) Saving and Using Cookies
Users have the autonomous right to allow cookies by changing options in the web browser, go through verification whenever cookie is saved, or refuse to save cookies. However, if cookies are not allowed, it may be difficult to use some of the services provided by the company.

4) How to Set Up or Refuse Cookies
Users can autonomously change the web browser's options to prevent cookies from being collected through the following path.
- Internet Explorer: [Tools] → [Internet Options] → [Privacy] → [Advanced] at the top of the web browser
- Chrome: [⋮] at the top right corner of the web browser → [Settings] → [Privacy & Security] → [Cookies and Site Data]
- Microsoft Edge: [⋮] at the top right corner of the web browser → [Settings] → [Site Permissions] → [Cookies and Site Data]
※ For other web browsers, follow the configuration method for each browser.

2. The company can use a variety of external web log analysis tools, such as Google Analysis, and users can refuse the usage of data through Google Analysis through the path below.
1) Blocking Google Analytics: https://tools.google.com/dlpage/gaoptout
※ For other web log analysis tools, follow the rejection method for each tool.

3. The company allows online customized advertising operators to collect behavioral information.
1) What is a customized online ad? It refers to a marketing technique that provides services in consideration of user characteristics by analyzing online usage behavior and access history.
2) Online customized advertising operators: Google, Facebook, Apple, AppsFlyer
3) Collected behavioral information: user's website visit history, app usage, and search history
4) Method of collecting behavioral information: automatic collection when a user visits a website or runs an app
5) Purpose of collecting behavioral information: providing customized advertisements based on user interest
6) Duration of retention and use of behavioral information: visits to web and app sites for 2 years
7) How to reject the collection of advertisement identifiers
Userscan choose whether to receive customized advertisements and autonomously turn off device options to prevent collection of advertisement identifiers through the following channels.
- Android Operating System (AOS): [Settings] → [Privacy] → [Ads] → [Delete advertising ID]
- Apple Operating System (iOS): [Settings] → [Privacy] → [Apple Advertising] → Choose to consent or withdraw
※ The path may differ depending on the OS version.

Article 12. Matters concerning consent and withdrawal of app access rights

"The company requests the user’s consent to access the functions and information of the user's mobile device device for the purpose of providing better service, and the user can withdraw or reset it at any time."

1. Android Operating System (AOS)
1) Android OS version 6.0 or higher
- How to withdraw access by category: [Settings] → [Privacy] → [Permission manager] → Choose a function → Choose to consent or withdraw
- How to withdraw access by Apps: [Settings] → [Apps] → Choose your Apps → [Permission] → Choose to consent or withdraw

2) Android OS version below 6.0
- Due to the nature of the operating system, access rights cannot be withdrawn by category. Instead, access rights can be withdrawn by deleting the app.
※ On mobile devices with Android versions below 6.0, there is a problem where the user cannot selectively agree with the app's optional access rights (where installation of the app is automatically considered as agreement). Therefore, if possible, it is recommended to upgrade the operating system of the user’s mobile device to Android OS version 6.0 or higher through software update. In addition, even if the operating system is upgraded, the access rights of existing apps will not be automatically changed. Therefore it is recommended to delete and reinstall the app to reset the access rights.

2. Apple Operating System (iOS)
1) How to withdraw access by category: [Settings] → [Privacy] → Choose a function → Choose a function → Select an app for consent or withdrawal
2) How to withdraw access by Apps: [Settings] → Choose your Apps → Choose to consent or withdraw

Article 13. Measures to Secure Safety for Personal Information

"The company is thoroughly implementing the following measures to secure personal information safety so that users' personal information is not lost, stolen, leaked, altered or damaged."
However, the company is not responsible for any problems caused by insufficient security management of the user's device or leakage of passwords, important information, and personal information due to the user's carelessness.

1. Technical measures
1) The company encrypts and stores the passwords entered by users when signing up and personal information designated by related laws in a safe manner. Only the user can know the encrypted password, check and/or change the personal information.
2) The company encrypts and protects communication sections within and outside the company to safely transmit personal information on the network.
3) The company blocks unauthorized access from outside through an intrusion blocking system and monitors personal information leakage.
4) The company regularly backs up personal information in case of an emergency and takes necessary safety measures to prevent users' personal information from being leaked or altered without permission by hacking or viruses.

2. Managerial measures
1) The companylimits access to personal information to a minimum, and limits the number of people who can process personal information to the following persons.
- Person directly in charge of handling user complaints, grievances, or answering inquiries
- Person who directs, manages, or supervises tasks related to personal information
- Person in charge of events, promotions, and delivery
- Person in charge of developing, maintaining, or operating a personal information processing system
- Person who inevitably processes personal information during other business processes
2) The company regularly provides mandatory annual training on personal information protection to the personnel and subcontractors who process personal information.
3) The company is doing its best to check the implementation of this privacy policy and compliance with personal information protection through in-house (personal) information protection organizations, so that if any problems are found, they are fixed as soon as possible.

3. Physical measures
1) The company keeps documents or removable storage media containing personal information in a safe place with locks.
2) The company has established access control procedures, and restricts physical access to the personal information processing system.

Article 14. Contact Us

If you have any opinions, questions, or complaints related to the company's privacy policy and practices, you can contact the company through one of the following channels:

- Department: Customer Center
- Email: support@ndream.com

In order to safely manage users' personal information, the company designates a person in charge of personal information protection as follows.

- Name: HAN SEO JO
- Position: Data Protection Officer & Chief Privacy Officer
- Email : privacy@ndream.com
- Phone : 02-2088-7020
- Address : West Building 16F, 135, Jungdae-ro, Songpa-gu, Seoul, Republic of Korea

Article 15. Others

The company may provide links to other companies' websites or materials. If you access another website by clicking the link provided by the company, please check the privacy policy on that website because this privacy policy is not effective in that website.

Article 16. Changes in the Privacy Policy

Due to various reasons such as changes in laws and regulations, services, business environments, and technical issues, the company may revise this privacy policy on a regular basis.

Addendum
This privacy policy will take effect on April 19, 2022.