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Infinity Nikki Personal Data and Privacy Policy

Infinity Nikki Personal Information and Privacy Protection Policy

Last updated: 2025.04.29

Effective date: 2025.04.29

Preamble

This Infinity Nikki Personal Information and Privacy Protection Policy (referred to as this “Privacy Policy”) applies to you (referred to as “you” or “user”) and Infold Pte. Ltd. with its registered office at 6 Raffles Quay, #14-06, Singapore (referred to as “we”, “us” or “Infold”).

We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, and otherwise process your personal information when you use our products and services. This includes interactions between you and us, as well as when you register to use the game products and services we provided (collectively referred to as the “Infold Game Services”).

For residents using Infold Game Services in South Korea, this 인폴드 유한책임회사 개인정보 수집 및 이용 안내 will apply. Similarly, for residents using Infold Game Services in Japan, this 『インフィニティニキ』プライバシーポリシー will apply. Infold may translate this Privacy Policy into multiple languages. Unless expressly stated otherwise, in the event of any inconsistency between a translated version and the English version of this Privacy Policy, the English version shall govern.

Please carefully read this Privacy Policy in its entirety, paying particular attention to the terms highlighted in bold. Make informed choices based on the guidance provided within this Privacy Policy. If you do not agree with this Privacy Policy, you should not use Infold Game Services.

If you are considered a child under the laws of your country or region of residence (e.g., under 14 years old in South Korea or under 13 years old in some other jurisdictions) or do not meet the minimum age requirement to use the “Infinity Nikki” game services as specified by your local laws, please refrain from using our services. If you are no longer considered a child under the laws of your country or region of residence, but you are a minor (the specific age is determined according to the definition of “adult” age in the laws of the country or region where you reside, for example, under 19 years old in South Korea, and under 18 years old in some countries and regions) or you are lacking the legal capacity to agree with a privacy policy, you must read this Privacy Policy accompanied by your parents (or legal guardians) and use Infold Game Services only after obtaining the consent of your parents (or guardians) to all the terms. The above requirements also apply to all amendments or modifications of this Privacy Policy.

We do not collect personal information from individuals under the age of 13 or below the minimum age required by the laws and regulations of your country/region to access Infold Game Services. If you are a guardian and discover that an individual under your care has used Infold Game Services or provided personal information, please terminate their use of Infold Game Services immediately and notify us promptly so we can take appropriate action. Additionally, we have included reminders in the “Supplementary Provisions for Specific Jurisdictions” Section of this Privacy Policy to address personal information protection requirements specific to various countries/regions. If your country/region is listed, please review the relevant regulations carefully.

If you have any questions or concerns about this Privacy Policy, please feel free to reach out to us using the contact details provided in the “Contact Us” Section. We will respond to you promptly.

This Privacy Policy will help you understand the following contents:

I. How We Collect and Use Your Personal Information

II. How We Use Cookies and Similar Technologies

III. How We Share Your Personal Information

IV. How We Store and Protect Your Personal Information

V. Your Rights to Manage Your Personal Information

VI. Protection of Minors’ Information

VII. Privacy Policy Updates

VIII. Contact Us

IX. Supplementary Provisions for Specific Jurisdictions

I. How We Collect and Use Your Personal Information

In compliance with applicable laws and regulations, and as necessary to provide our products and services, we may collect, store, and use the following information about you when you use Infold Game Services.

1. Game Account Services

(1) Login and identity verification. When you log into Infold Game Services, we will collect information associated with your Infold Account, such as the email address or third-party account you used to register or log in to your Infold Account and other information, as credentials for logging into Infold Game Services. Please note that if you use an Infold Account registered or logged with third-party accounts (such as Facebook Account or Google Account) to log in to your Infold Account and access Infold Game Services, we may obtain information related to your third-party accounts, which may include unique identifier, account name or nickname, personal avatar and list of friends, etc.. Please note that you can only register as our user and access Infold Game Services by providing true and accurate information; otherwise, you will be unable to log in or use all or part of Infold Game Services.

(2) Identity or age verification. In accordance with applicable laws, certain functions of Infold Game Services may require verification of your identity and age to determine your eligibility to use those functions. Providing false information may result in restricted access to those functions or limitations on your ability to use them.

(3) Profile Settings. You may set up your profile at your discretion. When setting up your profile, you may voluntarily provide or edit your nickname, tagline, avatar, profile card, and other profile information, which may be used to display your character and related information.

2. Ensuring the Operation of Infold Game Services

For the operation and provision of Infold Game Services, we may collect the following information based on the purposes and methods outlined below:

(1) To ensure your normal use of Infold Game Services, maintain the proper functioning of basic game features, optimize product performance, enhance your gaming experience, and ensure the security of your account, we may collect:

a. Your device or software information, that is, the device identifier provided by your mobile device, web browser, or other programs used to access our services (for example, Android ID, GAID for Android; IDFV, IDFA for iOS; motherboard serial number, CPUID, product ID, hard drive serial number, Machine GUID for PC; DUIDs for PlayStation; the validity, reset availability by the user, and acquisition method may vary for different identifiers. The unique device identification information is used solely during your use of the services we provide and is essential for service provision. This information is necessary to collect in order to provide the service.). Additionally, we collect device MAC address, device name, device settings and environment, device manufacturer, device time zone, device type, device model, device version, device serial number, OS type and version, system start-up time (mobile device only), system activation time (iOS only), IP address, carrier information, mntID (iOS only), network type (Wi-Fi/5G/4G/3G/2G; wired network for PC), Wi-Fi status, Wi-Fi MAC address, log information (Network diagnostic logs), application ID, client version, installer name, hardware and software feature information, hardware model, hardware serial number (SN), SD card data (internal/external SD card capacity, list of file names in SD card application cache directory), application name and version, SDK version, screen resolution and size (or device resolution), language region and country, battery and power status (mobile device only), CPU architecture information, timestamp, whether root/jailbreak, memory size and remaining memory, Google Advertising ID (Android only), emulator information (Android only), device landscape and vertical screen information, memory module information (PC only), graphics card information (PC only), whether to enable auxiliary functions (Android only), Baseband version (mobile device only), screen brightness (mobile device only), analog positioning switch (mobile device only), whether to enable ADB (Android only), SIM card status (mobile device only), acceleration sensor.

b. Your game log information, including login logs, item logs, game battle logs, purchase logs, network logs, and friend logs.This information allows you to view your game history on your device and is also used for purposes such as game operation analysis, customer service support, anti-cheating measures, and other analyses aimed at optimizing your gaming experience. To further enhance your experience, we may synchronize this data with updated game versions we provide to you in the future.

(2) To ensure the security of your game account and create a fair, healthy, and safe gaming environment, we collect your device information (device ID, device serial number, device manufacturer, device name, device type and version, device model, device style), device identifiers [for PC, such as boardID (motherboard UUID), CPUID, product ID, hard drive serial number, MachineGUID], memory module information (PC only), graphics card information (PC only), network identity information, network type, carrier information, game channel source, battery and power status (mobile device only), whether auxiliary functions are enabled (Android only), baseband version (mobile device only), system start-up time (mobile device only), screen brightness (mobile device only), mock location switch (Android only), whether ADB is enabled (Android only), SIM card status (mobile device only), used to combat behaviors that disrupt the fairness of the game or interfere with and damage the normal operation of game services (such as detecting piracy, scanning for cheats, anti-cheating).

(3) When you create, produce, upload, or publish content, or interact with other players through text or other means in Infold Game Services, we collect and store the content you send. This information is used to filter out inappropriate material, such as pornography, violence, abuse, and malicious advertisements, in order to maintain a safe and healthy online environment.

(4) When you use the purchase feature, we collect your top-up and purchase records to allow you to check your transaction history and, at the same time, ensure the security of your virtual items to the fullest extent.

(5) When you copy information within Infold Game Services for sharing or receive shared information, we need access to your device’s clipboard to enable functions such as obtaining benefits, activity participation and sharing. We will only access information related to Infold Game Services for verification purposes and will not store any such data to our server. We will not collect any unrelated information from your clipboard.

(6) In certain Infold Game Services, to facilitate the delivery of goods or services, you may need to provide payment status information, shipping address, and contact details with your consent. Specifically, to ensure the safe, smooth, and accurate delivery of goods or services, we may share some of your information with third-party logistics/delivery providers during the shipping and delivery process.

(7) When you contact us, we may collect your communication/call records and content or the contact information you provide. This allows us to contact you, assist in resolving issues, and record the actions and outcomes related to your request. We will also retain communication records for future reference.

(8) The information you provide when participating in our surveys, marketing activities, or testing activities is subject to your actual consent at the time. Please note that the submission and modification of such information may be subject to special rules on the relevant interface.

(9) When using Infold Game Services, we may contact you by phone or send you emails, text messages, notifications, or push alerts. You can unsubscribe on your device following our relevant prompts. Please note that in certain cases (such as service suspensions due to system maintenance), we may send service-related announcements, which are not of an advertising nature and may not be unsubscribed.

(10) Our various services (including in-game features such as “Friends”, “Snapshot”, taking “group photo” and other specific services) allow you to publicly share your relevant personal information or other game data not only within the game you use but also with all users of these services. This may include information you upload or publish in Infold Game Services (such as your nickname, tagline, avatar, profile card, and chat messages), your game data (such as character appearance and components, character game status, login logs, item collection status, match records, titles, and snapshots), your responses to content uploaded or published by others, as well as related log information (such as interaction relationships, levels, and rankings). Other users of Infold Game Services may also share information related to you (including log information). Specifically, our sharing features are designed to help you share game-related information with others according to your preferences. Shared information will remain in the public domain unless you delete it. However, even if you delete shared information, it may still be cached, copied, or stored independently by other users or third parties beyond our control, or retained in public domains by those users or third parties.

Therefore, please carefully consider the content you choose to make public, upload, publish, or share through Infold Game Services. In some cases, you may control who can view your shared information through privacy settings within certain services. If you wish to request the deletion of relevant information from Infold Game Services, please contact us to confirm the necessary steps. Please note that the deletion of personal information requires appropriate identity verification.

(11) Device permissions: During your use of our services, we will request permissions to access your system in specific business scenarios (the specific permissions may vary depending on the model and system version of the device you are using). We will seek your consent before obtaining permission, and you can choose whether to authorize it or not. You may manage (enable/disable) the aforementioned permissions at any time on the System Settings page of your device.

Please note that: by enabling any permission, you authorize us to collect and use the relevant information to provide you with the corresponding services. Disabling any permission withdraws, the corresponding authorization, and as a result, we will no longer collect and use the relevant information based on such permission, making it impossible to provide you with the services corresponding to such permission. However, your decision to disable any permission will not affect our previous collection and use of information based on your authorization.

Specially, please be aware that the access names may differ from one terminal to another due to variations in terminal devices and different operating systems. If you need to disable the permission enabled for using the above specific functions, most mobile devices will support your requirement. Refer to or contact the service provider of your mobile device for specific methods (for example, if your terminal device supports it, you may manage the aforementioned permission on the System Settings page of your terminal device at any time). If you have any questions, feel free to contact us through the channels set forth in the “Contact Us” Section of this Privacy Policy.

II. How We Use Cookies and Similar Technologies

1. We or our third-party partners may collect and use your information through cookies, web beacons, and other similar technologies and store such information. We use our own cookies, web beacons, and other similar technologies to recognize your device and provide information about how you use and interact with Infold Game Services. They support our ability to remember preferences, manage advertising, personalize experiences, and conduct data analytic.

2. Our third-party partners may place cookies, web beacons, and other similar technologies on our products and services. These technologies may collect non-personally identifiable information to analyze user interactions with Infold Game Services or assess the effectiveness of advertising efforts. We will require our third-party partners to fully comply with the relevant provisions of this Privacy Policy

3. You can manage or refuse cookies, web beacons, and similar technologies through your browser settings. Where required by law, we will seek your consent for the use of cookies.

III. How We Share Your Personal Information

1. Service Providers and Partners

We will share your personal information with our service providers, specifically including:

(1) Cloud service providers: Support data storage and basic maintenance.

(2) Security and basic function service providers: To enable essential functions such as engine services, push notifications, customer support, risk identification, error monitoring, performance data collection, reporting, and analysis, we collaborate with third-party service providers and share necessary information. For more details, you can access the privacy policies or official websites of these providers via the links below:

Google LLC: https://policies.google.com/privacy , https://firebase.google.com/terms

ShareFun Network Limited: https://aihelp.net/privacypolicy/

Aceville Pte Ltd.: https://intl.anticheatexpert.com/#/doc-center/8fc4c1195346a2c74e472881bca42c4010698921

Alibaba Cloud (Singapore) Private Limited: https://www.alibabacloud.com/help/en/sls/?spm=a2c63.p38356.0.0.6fee2222HNy36r

Epic Games, Inc: https://www.epicgames.com/site/en-US/privacypolicy?lang=en-US

(3) Third-party platform partners: You may use an Infold Account registered or logged with third-party accounts (such as Facebook Account or Google Account) to log in to your Infold Account and access Infold Game Services. For more details, you can access the privacy policies of these third-party platform partners via the links below:

Apple, Inc.: https://www.apple.com/legal/privacy/en-ww/

Google LLC: https://policies.google.com/privacy#infocollect

Meta Platforms, Inc.: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

Sony Interactive Entertainment Inc.: https://www.playstation.com/en-sg/legal/psn-terms-of-service/?country-selector=true

Valve Corporation: https://store.steampowered.com/privacy_agreement/?snr=1_44_44_

(4) Data analysis and advertising service providers: We may share your device identifiers, device information, and other relevant data with our partners for purposes including data analysis, advertising placements, attribution, and similar activities. However, we will not provide personalized advertisements. For more details, you can access the privacy policy of the service providers via the links below:

AppsFlyer Ltd.: https://www.appsflyer.com/legal/privacy-policy/

(5) Payment service providers. When you purchase game coins or other virtual items, we share relevant information, such as your order number and order details, with payment service providers to facilitate the transaction. Your financial account information will be collected and processed exclusively by the payment service providers in accordance with their privacy policies. We do not collect or store your financial account information. For more details, you can access the privacy policies of the service providers via the links below:

Google LLC: https://policies.google.com/privacy#infocollect

Apple, Inc.: https://www.apple.com/legal/privacy/en-ww/

Sony Interactive Entertainment Inc.:
https://www.playstation.com/en-sg/legal/psn-terms-of-service/?country-selector=true

Adyen N.V.: https://www.adyen.com/privacy-policy

Checkout APAC Pte.Ltd: https://www.checkout.com/legal/privacy-policy

PayPal Hong Kong Limited: https://www.paypal.com/hk/legalhub/paypal/privacy-full

(6) The information sharing based on the sharing features provided by Infold Game Services, which is initiated by you voluntarily. Infold Game Services may include features that allow you to share information publicly or with others. When you use these sharing functions, information such as your avatar, nickname, and other content you choose to share may be visible to third-party platforms or recipients.

2. Our Affiliated Companies

To provide you with integrated services through the unified Infold Account system, enhance your convenience in accessing and managing our products and services, and ensure account security, we will share your personal information under Infold Account (such as your registered email address, avatar, nickname, and personal profile) with our affiliated companies as necessary.

Some of Infold Game Services you access and use may be supported by our affiliated companies. We may share your personal information with our affiliated companies to achieve the data processing purposes stated in this Privacy Policy. In this case, we will only share the necessary personal information within the purposes and scope specified in this Privacy Policy.

3. Legal Obligation

We may disclose your personal information to law enforcement agencies, courts, government authorities, or other third parties under certain circumstances, including to comply with legal obligations, prevent fraud, assist in investigations by competent authorities, protect our rights or those of other users, or for other legitimate purposes.

4. Merger and Sale

As our business continues to grow, your information may be shared with third parties as part of a corporate transaction, including but not limited to mergers, acquisitions of all or part of our business, asset transfers or other similar transaction, which may affect your personal information. We will notify you of relevant updates via push notifications, emails, announcements, and other means. We will also ensure that any new managing entities are obligated to protect your personal information in compliance with applicable laws, regulations, and standards equivalent to or exceeding those outlined in this Privacy Policy.

IV. How We Store, Transfer and Protect Your Personal Information

1. Retention

We retain information for as long as necessary to operate Infold Game Services and for the purposes outlined in this Privacy Policy. We also retain information to fulfill contractual and legal obligations, pursue legitimate business interests (such as improving and developing service, and enhancing its safety, security, and stability), and for the exercise or defense of legal claims.

2. Global Operation

To provide you with the highest quality services, we embrace a strategy of diversification and globalization, with our affiliated companies operating worldwide. Under the user agreement between you and us, your personal information may be processed on servers located outside your place of residence. Regardless of the server location, we will implement appropriate measures in line with the protection standards outlined in this Privacy Policy and applicable legal requirements to safeguard your rights. The servers supporting Infold Game Services are located in [Frankfurt, Germany], [Singapore], [Virginia, USA], and [Tokyo, Japan].

Infold is a global gaming enterprise with suppliers located worldwide. In accordance with the principles of necessity and data minimization, we may access certain information from various locations. Our support, engineering, and other teams around the world may process your information from places outside your country of residence, such as Singapore.

3. Transfer

If the information we collect must be transferred across borders, we will ensure that such transfers are conducted in compliance with applicable laws and regulations.

4. Security Measures

We will implement reasonable and necessary security measures in line with industry best practices to minimize the risks of information loss, misuse, unauthorized access, or disclosure. For instance, we may use encryption technologies, such as SSL, to protect the personal information you provide when using certain products or services. We also regularly review our security measures to consider available new technology and methods. However, please be aware that due to technological limitations and potential malicious threats, even with our best efforts to enhance security, we cannot guarantee 100% information security. Additionally, the system and communication networks you use to access our Services may encounter issues beyond our control.

V. Your Rights to Manage Personal Information

We understand your concerns regarding personal information and are committed to ensuring your rights to access, correct, delete, and withdraw authorization for your personal information. We strive to empower you with the necessary tools to safeguard your privacy and security. Your rights include:

1. Right to Access.

You can refer to the relevant instructions or settings we provide to access the personal information you have shared with us, such as avatar, nickname, player number, tagline etc. (if applicable). If you encounter any issues during the access process or need to retrieve additional personal information that is not accessible through the aforementioned methods, you can contact us using the contact details provided in this Privacy Policy.

2. Right to Correct or Modify.

If you find that the personal information you provided to us contains errors, is incomplete, or needs to be updated, you have the right to correct or modify it within our products and/or services.

(1) For certain personal information, we offer settings within specific product features that allow you to directly view, correct, or modify your data. For example, to update your “profile picture” in the game, follow this path: Pear-Pal → Click on your avatar → Select the edit button.

(2) For any challenges you may face while exercising the rights mentioned above, or in cases where online self-correction or modification services are unavailable, you may submit a request to correct or modify your personal information through the feedback, error reporting, or customer service channels we have announced, subject to verification of your identity. Provided the requested correction or modification does not compromise the objectivity or accuracy of the information and unless otherwise stipulated by applicable laws and regulations, we will assist with your request. However, for security and identification purposes, certain initial registration information provided during account creation may not be modifiable.

3. Right to Delete.

You have the right to delete your information or request that we delete it. However, if retention is required by applicable laws, regulations, or to fulfill legal obligations, we may retain your information and will inform you accordingly.

4. Right to Withdraw Authorization.

Even if we have obtained your consent to collect or process your personal information, you may withdraw your consent at any time. Please note that, once you withdraw your authorization, we will no longer be able to provide you with the specific functions and/or services related to the withdrawn authorization. However, the withdrawal of your consent will not affect the processing of personal information carried out prior to your withdrawal.

5. Right to Obtain a Copy of Your Personal Information.

You have the right to request a copy of your personal information. To do so, please contact us using the methods outlined in this Privacy Policy. We will respond to your request within a reasonable timeframe, as required by applicable law.

6. Right to Object.

If we process your personal information based on our legitimate interests, you have the right to object to such processing. However, we may continue to process your personal information if we have compelling legitimate grounds or for the establishment, exercise, or defense of legal claims.

7. Right to Delete Your Account.

You may request to delete your Game Account through customer service or via other methods publicly announced by us. Once your Game Account is deleted, you will no longer be able to log in or access our products and services using that Account. Additionally, any rights and interests accumulated during the use of the “Infinity Nikki” product and services that have not been fully consumed, as well as any future overdue interests and other associated rights, will be forfeited. All content, information, data, and records linked to the Game Account will be deleted or anonymized. Once the account deletion is complete, it cannot be restored. You may also delete your Game Account by deleting your Infold Account. For further details on the prerequisites, procedures, conditions, and consequences of deleting your Infold Account and Game Account, please refer to the information provided on the deletion page or reach out to our customer service team.

8. How We Respond to Your Above Rights Requests.

We will reply to you as soon as possible within 15 working days (or the legal period stipulated by the applicable law) after receiving your request and verifying your user identity. Before we can respond to your request to exercise any of the rights listed above, you may be asked to verify your identity or game account details, or provide additional information to help us understand your request. If you have any questions when disposing of your personal information, you can communicate and solve them with us through the contact information published in “Contact Us” Section of this Privacy Policy. However, if the laws, regulations, or executive orders of the relevant administrative or judicial authorities in your location prohibit us from responding, we may not be able to address your request. Additionally, certain requests may need to be processed through the application store. We may be unable to fulfill your request until the application store completes the necessary procedures or provides a response.

VI. Protection of Minors’ Information

Please note that we do not collect personal information from a child (as defined by the applicable laws in your country or region. For example, in South Korea, “child” refers to individuals under 14 years old, whereas in some other countries or regions, it refers to individuals under 13 years old). If you are a child, you must immediately stop using Infold Game Services.

If you are above the age defined as a child in your country or region but you are a minor (the specific age is determined according to the definition of “adult” age in the laws of the country or region where you reside, for example, under 19 years old in South Korea, and under 18 years old in some countries and regions) or you are lacking the legal capacity to agree with a privacy policy, you must read this Privacy Policy accompanied by your parents (or legal guardians) and use Infold Game Services only after obtaining the consent of your parents (or guardians) to all the terms.

If you are a guardian of minor(s) and discover that a minor under your care has used our services or provided personal information, please terminate their use of our services immediately and notify us promptly so we can take appropriate action. If you wish to query or delete your information, please refer to the “Your Rights to Manage Your Personal Information” Section. Our customer service team may need to verify and confirm the guardianship and your relationship with the ward. Once confirmed, we will assist you in deleting the information and the corresponding Game Account as per your request.

VII. Privacy Policy Updates

We reserve the right to modify or update this Privacy Policy as necessary. When changes are made, we will notify you by updating the “Last updated” date at the top of this Privacy Policy or through any other notice required by applicable law. We encourage you to periodically review this Privacy Policy to stay informed about our current privacy practices.

VIII. Contact Us

1. We have established a dedicated department to protect your personal information in accordance with this Privacy Policy. If you have any questions, feedback, or suggestions regarding this Privacy Policy, our privacy measures, or matters related to your information, please feel free to contact us via email at [dpo@infoldgames.com].

2. We will generally respond within 15 working days (or the legally required period under applicable law) upon receipt of your questions, comments, or suggestions, and after verifying your user identity, unless otherwise specified by the laws and regulations of the jurisdiction in which you use Infold Game Services.

IX. Supplementary Provisions for Specific Jurisdictions

Certain jurisdictions’ laws require additional terms for users of the game services, which are outlined in this section.

If you are a user reside in one of the jurisdictions below, the terms specific to your location will apply to you in addition to those detailed in the Privacy Policy above.

[Australia]

If you are using Infold Game Services in Australia, except for the provisions specified in the main text of this Privacy Policy, the following special terms also apply to you:

Overseas Recipients

We take reasonable steps to ensure that recipients of your personal data located outside Australia handle your personal data in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third-party recipients.

Our affiliated companies, located outside of Australia, are given very limited access to your personal information for the purpose of providing certain features of Infold Game Services. If you have any questions, please contact us through the methods provided in the “Contact Us” Section of this Privacy Policy.

Transacting Anonymously

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the game services. You acknowledge that if you do not provide us with your personal data, we may be unable to provide you with access to certain features or sections of the game services, including social media integration and in-game purchases.

Your Rights

Subject to limited exceptions under applicable laws, you have the right to access, and correct inaccuracies in your personal information and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may refer to “Your Rights to Manage Your Personal Information” Section or contact us through the methods provided in the “Contact Us” Section of this Privacy Policy.

[California, United States]

If you are using Infold Game Services in California, United States, except for the provisions specified in the main text of this Privacy Policy, the following special terms also apply to you:

Rights under the CCPA

If you are a California resident, you have the right to:

· Request we disclose to you free of charge the following information covering the 12 months preceding your request:

o the categories of personal data about you that we collected;

o the categories of sources from which the personal data was collected;

o the purpose for collecting personal data about you;

o the categories of third parties to whom we disclosed personal data about you and the categories of personal data that was disclosed (if applicable) and the purpose for disclosing the personal data about you; and

o the specific pieces of personal data we collected about you;

· Request we delete personal data we collected from you, unless CCPA recognizes an exception;

· Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

We will acknowledge receipt of your request within 10 business days of receiving it and provide information on how we will likely handle the request. We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

You may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us at dpo@infoldgames.com.

[Canada]

If you are using Infold Game Services in Canada, except for the provisions specified in the main text of this Privacy Policy, the following special terms also apply to you:

· If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at dpo@infoldgames.com.Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal data by Infold Game Services providers.

· Where we use service providers who might have access to your personal data, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal data, and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

[EEA, UK and Switzerland]

If you are using Infold Game Services in EEA, UK and Switzerland, except for the provisions specified in the main text of this Privacy Policy, the following special terms also apply to you:

The “Your Rights to Manage Your Personal Information” Section of this Privacy Policy outlines the rights you have regarding your personal information. In addition, you also have the right to:

· Restrict the processing of your personal information;

· Object to the processing of your personal information.

Legal basis for processing your personal data

We may only use your personal data when we have a “legal basis” to do so. The legal basis for collecting and using the personal data, as outlined in the Privacy Policy above includes:

· To establish and perform our contract with you (i.e. our “Infinity Nikki User Agreement”) and to provide Infold Game Services;

· To achieve our or our partners’ legitimate interests, where those interests are not overridden by your data protection interests of fundamental rights and freedoms, e.g. to protect our legal rights, to pursue or defend legal claims, to improve Infold Game Services;

· To collect or use your personal data for specific purposes;

· To comply with our legal obligations under applicable laws and regulations;

· To protect your vital interests or those of another person (for example, another player) or us , e.g. against fraud and violations of our terms;

· We typically do not collect sensitive or special category personal information, where we do this, it will be on the grounds of your consent or other applicable lawful basis.

Data Transfers

By accepting and consenting to this Privacy Policy, you consent to the transfer of your personal data to third parties (if any), which may include the cross-border transfer of your data to any country where we have databases or affiliates and, in particular, to the jurisdictions as described in “How We Store and Protect Your Personal Data” Section.

Where we transfer your personal data to countries and territories outside of the EEA, UK or Switzerland, which have been formally recognized as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission, where applicable, to transfer your personal data.

Where the transfer is not subject to an adequacy decision, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Policy. The safeguards we use are the European Commission’s Standard Contractual Clauses as issued on 4 June 2021, including the UK Addendum, the UK International Data Transfer Agreement permitted under Article 46 of the UK GDPR, and/or their approved equivalent for Switzerland. This is how transfers of personal data between us and other companies will be safeguarded. We will protect personal data that we process from Europe in accordance with European Union data protection law.

Data Protection Supervisory Authority

To lodge a complaint with your national or regional data protection supervisory authority, please contact the competent authority.

[Indonesia]

If you are using Infold Game Services in Indonesia, except for the provisions specified in the main text of this Privacy Policy, the following special terms also apply to you:

Parental and Guardian Consent

By accessing and/or using Infold Game Services, you confirm that you are at least 21 years of age or married or not under guardianship. If you are under 21 years old and not married, or under guardianship:

· you must obtain approval from your parents or legal guardian; and

· your parents or legal guardian are responsible for: (i) all actions you take in connection with your use of Infold Game Services; (ii) ensuring that your using of Infold Game Services does not violate any applicable laws and regulations regarding child protection.

· If you do not have consent from your parent or legal guardian, you must cease accessing Infold Game Services.

Data Retention

We retain your information for as long as necessary to provide Infold Game Services to you. In certain cases, we may retain your data for up to five years or longer if legally required, to comply with our legal obligations or to support the exercise, or defense of legal claims.

[New Zealand]

If you are using Infold Game Services in New Zealand, except for the provisions specified in the main text of this Privacy Policy, the following special terms also apply to you:

Overseas Recipients

We take reasonable steps to ensure that recipients of your personal data located outside New Zealand handle your personal data in a manner that is consistent with privacy laws of New Zealand. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third-party recipients.

Our affiliated companies, located outside of New Zealand, are given very limited access to your personal information for the purpose of providing certain features of Infold Game Services. If you have any questions, please contact us through the methods provided in the “Contact Us” Section of this Privacy Policy.

Transacting Anonymously

Your Rights

[Philippines]

If you are using Infold Game Services in Philippines, except for the provisions specified in the main text of this Privacy Policy, the following special terms also apply to you:

Minimum Age.

You must be at least 18 years of age to be able to use the game services.

Your Rights

You are entitled to the following rights:

· Right to be informed: You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.

· Right to object. You may in certain circumstances have the right to object to the processing of your personal data, including processing for direct marketing, automated processing or profiling.

· Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal data.

· Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal data and have us correct it, unless the request is vexatious or otherwise unreasonable.

· Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal data.

Consent

By consenting to this Privacy Policy, you consent to us:

· collecting and processing your personal data as described in the “How We Collect and Use Your Personal Information” Section in the Privacy Policy above;

· sharing your personal data with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and transferring or storing your personal data in destinations outside the Philippines as described in the section “How We Store and Protect Your Personal Information” above.

[Singapore]

If you are using Infold Game Services in Singapore, except for the provisions specified in the main text of this Privacy Policy, the following special terms also apply to you:

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at dpo@infoldgames.com. If you have any inquiries with respect to how we collect, processing and share your personal information, please contact us at dpo@infoldgames.com.

[Thailand]

If you are using Infold Game Services in Thailand, except for the provisions specified in the main text of this Privacy Policy, the following special terms also apply to you:

By accepting this Privacy Policy, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the game services.

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal data which is stored by us, to the extent provided by the act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at dpo@infoldgames.com.

We will give you notice of any material changes to this Privacy Policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries other than Thailand, to the extent and for the purpose provided by this Privacy Policy.

[Japan]

If you are using our Services in Japan, the 『インフィニティニキ』プライバシーポリシー, as well as the following additional terms apply:

If you are under the age of 15, please ensure that your parent or legal guardian reviews this with you. If you do not have consent from your parent(s) or legal guardian(s), and they are unwilling to open an account in their name, you must stop accessing Infold Game Services.

If you are reviewing these terms as the parent or legal guardian of a user under the age of 15, you hereby confirm that the user is at least 13 years old, and that you have read, understood, and acknowledged both this Privacy Policy and the Infinity Nikki User Agreement. You also consent to the minor under your guardianship’s use of Infold Game Services, and our processing of that minor’s personal data in accordance with this Privacy Policy.

[South Korea]

If you are using Infold Game Services in South Korea, the 인폴드 유한책임회사 개인정보 수집 및 이용 안내, as well as the following additional terms apply.

Children: Our Services are not intended for children under the age of 14.

We will delete personal information once the purpose for its collection, as consented to by you, has been fulfilled, or once the periods and purposes for which you consented, as outlined in this Policy, have expired. However, we will retain your personal information for any statutorily prescribed periods, as applicable, including but not limited to the following:

Act on Consumer Protection in Electronic Commerce:

Records of order cancellations, payments for purchased items: 5 years;

Records of consumer complaints or disputes: 3 years;

Records of advertisements and labels: 6 months.

Protection of Communications Secrets Act:

Records of your visits to our website: 3 months.