PRIVACY POLICY

for Com2uS Online Event Page

 

Table of Contents

  1. 1. Introduction
  2. 2. Who We Are
  3. 3. Information We Collect and How We Use It
  4. 4. Retaining and Deleting Personal Data
  5. 5. Transfer of Personal Data to Third Country
  6. 6. Security of Your Information
  7. 7. Our Policy Concerning Children
  8. 8. Your Privacy Rights
  9. 9. Change/Update to Privacy Policy
  10. 10. Links 
  11. 11. Data Protection Officer and Representative
  12. 12. Questions

 

 

  1. 1. Introduction

 

We take privacy seriously, and we are committed to protecting personal data of our users (“you” or “User”).  We provide this privacy policy (the “Privacy Policy”) to help you understand how we collect, store, use, manage, share, and disclose your personal data you provide or we collect.  This Privacy Policy applies where we are acting as a data controller with respect to your personal data and is limited to data collected or received by us through your use of our services.

 

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  1. 2. Who We Are

 

Com2uS Corporation (“Com2uS”), jointly with Gamevil Com2uS Platform Inc. (“GCP” and collectively with Com2uS, “we” or “us”), provide Com2uS’s mobile games (“Com2uS Games” or “Games”) and related services. Specifically, we operate separate online pages providing online promotion events, including, without limitation, pre-registration event (collectively, our “Online Event(s)”). 

 

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  1. 3. Information We Collect and How We Use It

 

Email Address Necessary for Sending Event Rewards

When you participate in the Online Event, we collect your email address which must be processed so that we can send you corresponding rewards you are entitled to receive for your participation.

As we have limited capability in sending emails to the participants, we may provide your email address to third party company(s), such as Cheom Soft, who will perform email delivery service solely as directed by us.

We collect, process and provide your email address because we have a legitimate business interest in providing necessary services, such as identifying participants to each Online Event and sending rewards to those who are qualified to receive such rewards via email.  The above said legitimate interest does not override your interests, rights and freedoms to protect information about you.  Also, we process your email address to discharge our contractual obligations arising from your registration of Online Events.

 

Additional Information

Furthermore, upon your explicit consent, we may also collect and process your email address to provide promotional/marketing information regarding Com2uS Games via e-mail newsletters.  Upon your consent, we will use your email address to send you emails about the Online Events, Com2uS Games, and other related services.

 

Usage Data through Automated Means

When you access our Online Event page, we may also collect your usage statistics about your interactions with our services.  Such usage data is collected through the use of server log files and/or automated means.  We and our marketing partners and analytics service providers use technologies may use “cookies” and other technologies such as pixel tags and web beacons, clear GIFs on certain web pages to analyze your use of our services, advertising and web pages, to customize, improve the same, to measure promotional effectiveness, and to promote trust and safety. We collect and process your usage data because we have a legitimate business interest in providing the services to you that do not override your interests, rights and freedoms to protect information about you.  You are always free to decline our cookies if your browser or device permits, although doing so may interfere with your use of some of our services, advertising and web pages.

 

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  1. 4. Retaining and Deleting Personal Data

 

We retain your information only for the period of time as necessary to achieve the particular purpose for which the information was processed.  Typically, we retain your information for 1 month after the Online Event period expires and the relevant rewards are sent via email.

Notwithstanding, we may retain your information insofar as such information will be processed solely for archiving purpose in compliance with our legal obligation, public interest, scientific or historical research purposes or statistical purposes, subject to appropriate safeguards, in accordance with the data protection laws, for your rights and freedoms.  Note that in some circumstances, you have the right to request us to delete the information.  The appropriate safeguards shall ensure that technical and organizational measures are in place to ensure respect for the principle of data minimization.

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  1. 5. Transfer of Personal Data to Third Country

 

Your personal data may be transferred globally, either within or outside the European Economic Area (“EEA”), including to a country or territory that may not have equivalent data protection standards, on the basis of your consent.  In all cases, appropriate security measures for the protection of personal data will be applied in those countries or territories, in accordance with applicable data protection laws.  For example, we will obtain your explicit consent when your personal data is transferred to South Korea, which is currently under review of the European Commission adequacy decision.

 

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  1. 6. Security of Your Information

 

We take appropriate technical and organizational measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, sensitive data that you share and we collect and store.  Despite our efforts to enhance a security level of our services, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.  We strongly encourage you not to share your account password with any third parties for any reasons.  Also please note that email and messaging systems are not considered secure, so we discourage you from sending us personal data through these mediums.  If you have questions regarding the security measures of our services, please contact us at privacy@com2us.com.

 

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  1. 7. Our Policy Concerning Children

 

With regard to participants under the age of 16, we do not process their personal data for marketing purposes without a valid consent from their legal representative (e.g. parents).

We make reasonable efforts to verify if consent from or any kind of contract concluded with such children is valid by offering users age verification methods and by obtaining clear consent from children’s legal representatives.  If we learn that we have inadvertently gathered personal data from such children, we will take reasonable measures to promptly erase such information from our records.  If children under 16 or their legal representative ask us to cease processing or profiling of the child’s personal data for the purposes of direct marketing, we will immediately do so.

 

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  1. 8. Your Privacy Rights

 

  1. 8.1 Right to Access

You are entitled to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information.  That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.  Provided, the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You can access your personal data by contacting us at privacy@com2us.com.

 

  1. 8.2 Right to Rectification

You are entitled to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

You may change or update the profile information by visiting https://withhive.com/help/inquire or by contacting us at privacy@com2us.com.

 

  1. 8.3 Right to Erasure

In some circumstances you are entitled to the erasure of your personal data without undue delay.  Those circumstances include: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing; (iii) you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and (iv) the personal data have been unlawfully processed.  However, there are exclusions of the right to erasure.  The general exclusions include where processing is necessary: (a) for exercising the right of freedom of expression and information; (b) for compliance with a legal obligation; or (c) for the establishment, exercise or defense of legal claims.

If you choose not to participate in the Online Event, we will immediately delete your email address. You may request erasure of your information by visiting https://withhive.com/help/inquire or by contacting us at privacy@com2us.com.

 

  1. 8.4 Right to Restrict Processing

In some circumstances you are entitled to restrict the processing of your personal data.  Those circumstances are: (i) you contest the accuracy of the personal data; (ii) processing is unlawful but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and (iv) you have objected to processing, pending the verification of that objection.  Where processing has been restricted on this basis, we may continue to store your personal data.  However, we will only otherwise process it: (a) with your consent; (b) for the establishment, exercise or defense of legal claims; (c) for the protection of the rights of another natural or legal person; or (d) for reasons of important public interest.

You may request restriction of the processing of your information by visiting https://withhive.com/help/inquire or by contacting us at privacy@com2us.com.

 

  1. 8.5 Right to Object to Processing

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You may object to the processing of your information by visiting https://withhive.com/help/inquire or by contacting us at privacy@com2us.com.

 

  1. 8.6 Right to Object to Processing for Direct Marketing Purposes

You are entitled to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.

You may object to the processing of your information for direct marketing purposes by visiting https://withhive.com/help/inquire or by contacting us at privacy@com2us.com.

 

  1. 8.7 Right to Object to Processing for Scientific, Historical, or Statistical Purposes

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

You may object to the processing of your information for scientific, historical or statistical purposes by visiting https://withhive.com/help/inquire or by contacting us at privacy@com2us.com.

 

  1. 8.8 Right to Data Portability

To the extent that the legal basis for our processing of your personal data is:

  • - consent; or
  • - that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format and the right to have your personal data transmitted to another controller.  However, this right does not apply where it would adversely affect the rights and freedoms of others.

You may request to receive your information by visiting https://withhive.com/help/inquire or by contacting us at privacy@com2us.com.

 

  1. 8.9 Right to Complain to a Supervisory Authority

If you consider that our processing of your personal data infringes data protection laws, you are entitled to lodge a complaint with a supervisory authority responsible for data protection.

You can find more details of the supervisory authority in your country by visiting

http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

 

  1. 8.10 Right to Withdraw Consent

To the extent that the lawful basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time.  Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may withdraw your consent at any time by visiting https://withhive.com/help/inquire or contacting us at privacy@com2us.com.

You may also exercise any of your rights in relation to your personal data by written notice to us at privacy@com2us.com

 

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  1. 9. Change/Update to Privacy Policy

 

We may amend, at our discretion, any portion of this Privacy Policy at any time by posting or displaying the amended Privacy Policy within and/or on Com2uS Games, Com2uS branded website, or the HIVE Platform.  You will be deemed to have accepted such amendments by continuing to use our services.  Except as otherwise stated, any such amendments will be automatically effective after they are initially posted.  Our policy will be regularly updated.  We will notify you of the changes where required by law to do so.  This policy was last updated on May 25th, 2018.

 

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  1. 10. Links

 

The Online Event page may contain links to other websites. The fact that the Online Event page links to a website or presents a banner ad or other type of advertisement does not mean that we endorse or authorize that third party, nor is it a representation of our affiliation with that third party.  We are in no way responsible for the privacy policies of these other websites to which you choose to access from our services.  It is your responsibility to read the privacy policies of these other websites when exiting the Service.

 

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  1. 11. Data Protection Officer and Representative

 

Our data protection officer can be reached at:

Name : Kirk Olaf Dettmann

Email : privacy@com2us.com

Address : Wattstrasse 10, 13355 Berlin, Germany

 

Our representative can be reached at:

Name : GAMEVIL COM2US Europe GmbH

Email : privacy@com2us.com

Address : Wattstrasse 10, 13355 Berlin, Germany

 

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  1. 12. Questions

 

If you have any questions regarding our Privacy Policy and/or practices, please email us at privacy@com2us.com

 

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