This privacy policy informs you of your choices and our practices regarding any personal information you provide to us. Your use of “LootBar”platform distributed by GEARUP PORTAL PTE. LTD. (“we” or “us”) involves the collection and use of your personal information. It is important for you to understand how this happens and how you may control it.
When you contract to use“LootBar”platform (the “Services”), you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using and storing your personal information, as described in this policy.
You acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy, you must not use the Services. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.
If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us through the in-Service customer service “Contact support” .
This section describes the different types of personal information we/third party collect(s) and how we/third party collect(s) it. We/third party will collect and use the following information about you:
• Information you give us.
You give us information about you:
o when you register for the Services (including your nominated nickname, and information we import from your SNS account, game account and email address in order to set up your profile, including your name as it appears on your game account profile and your profile picture or other pictures you uploaded to us);
o when you secure your account for the Services (including information you provide to help secure the account, including but not limited to your email address, security questions, etc.);
o when you submit your contact details to us (including your name, email address) as part of promotional activities for the Services; and
• Information we collect about you.
We automatically collect certain data from you when you use the Services, including your IP address and device information (such as device type, network data, OS) and information regarding your use of the Services, such as date and time stamps of actions. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.
Our Service is not intended for children and we do not knowingly collect information from children. In some cases, we may ask the user to provide us with their date of birth date for age verification. If such information indicates the user is under the age stipulated by the applicable laws and deemed as child under such laws, we will not collect further personal information from the child until a parent/guardian’s verifiable consent is obtained.
If you are in the United States:
With parental consent, we may collect personal information from children under the age of thirteen (13). If we learn that we have collected or received personal information from a child under the age of thirteen (13) without parental consent, we shall immediately take the necessary steps to ensure that such information is deleted from our system’s database. Parents have the right to review their child’s personal information; to have their child’s personal information deleted; and to refuse further collection, use, and/or disclosure of their child’s personal information by notifying us.
As a parent, you understand that we have a legitimate interest in providing your child’s personal information collected via the Service to external providers for the purpose of administering or providing the Service. Anyone under the age of thirteen (13) must seek and obtain parent or guardian permission to use our Service. For additional information, you may contact us through the in-Service customer service “Contact support”.
We will use the information in the following ways and in accordance with the following legal bases:
Registration Information (game ID, Open ID, nick name, email address, security questions, profiling photo): We use Registration Information to set-up user accounts, allow users to use Services, maintain and secure the user accounts with us. We use this information with your consent to this Privacy Policy.
Device Information (Device ID, Device Type, Operating System, CPU, RAM, IP address, MAC address): We use this information to provide and improve the Services such as: to allow users to download and install the application on their devices; to record and keep track of requests from users of the Services; to detect the user network and device status when the user is using the Services; and to correct bugs or errors that occur when the user is using the Services. Use of Device Information is necessary to perform our contract with you to provide the Services.
Contact Information (Name, Email, Phone Number): We use this information to send notifications to users to inform them of our promotional activities and any rewards they are entitled to. We use this information with your consent to this Privacy Policy.
In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers. Our servers are hosted on cloud servers such as Amazon Web Services which located in Japan. Your information may be transferred to and processed in countries outside the country you are located. We will take steps necessary to comply with applicable legal requirements.
We share your personal information with selected third parties in and outside your country, including:
• third-party vendors that provide services in support of the Services, such as Amazon Web Services (“AWS”) for the purpose of hosting the Services;
• law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to: (1) comply with a legal obligation, process or request; (2) enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; (3) detect, prevent or otherwise address security, fraud or technical issues; or (4) protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection); and
We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We deploy a firewall and other security measures (such as encryption) commensurate to industry standards to prevent unauthorized access to your personal information. Your personal information will remain subject to our technical and organizational controls and our policies and procedures (including this Privacy Policy).
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.
We will retain all of your personal information for the lifetime of your use of the Services (i.e. until account deletion in accordance with your request).
In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws).
Your rights will be determined by the country in which you reside. Many counties have specific laws relating to privacy. We seek to abide with all relevant national laws.
For Japanese Residents:
The Act on the Protection of Personal Information (“APPI”) provides you with certain rights regarding your personal information in certain circumstances and subject to certain exceptions. This section describes your APPI rights and explains how to exercise those rights.
We will respond to any requests for disclosure, etc. (meaning requests for notification of the purposes of use, for disclosure, revision, deletion or addition, and for the suspension of use or third-party provision) as follows:
(1)Notification of Purposes of Use or Disclosure
You may request us to provide notification of the purposes of use or to disclose his/her personal data or records of third-party provision in accordance with the procedures separately prescribed by us, except where:
(i)Such disclosure may damage the life, body, property or any other rights and interests of the data subject or any third party;
(ii)Such disclosure may significantly obstruct the proper performance of our duties;
(iii)Such disclosure violates the laws and regulations; or
(iv)It cannot be confirmed that such request for disclosure had been made by the data subject him/herself.
Please note that, when making a request for notification of the purposes of use or for the disclosure of your personal data or records of the third-party provision thereof, you may be charged a disclosure fee in accordance with the procedures separately prescribed by us.
(2)Revision, Deletion or Addition
You may make a request for the revision or deletion of, or the addition to, his/her personal data in accordance with the procedures separately prescribed by us. In that case, we will inspect the circumstances without delay, within the scope necessary to achieve the purposes of use, and will revise, delete or make additions to such personal information based on the results of such inspection.
(3)Suspension of Use or Third-Party Provision
You may make a request for the suspension of use or third-party provision of personal data in accordance with the procedures separately prescribed by us. In that case, we will appropriately respond to such request in compliance with APPI.
For California Residents:
The CCPA provides you with certain rights regarding your personal information in certain circumstances and subject to certain exceptions. This section describes your CCPA rights and explains how to exercise those rights.
The Right To Know
You may have the right to request that we disclose to you certain information about our collection and use of your personal information over the preceding twelve months.
Once we receive and confirm a verifiable consumer request, we will disclose to you the following information responsive to your request:
• The categories of personal information we collected about you.
• The categories of sources from which the personal information was collected.
• The categories of third parties to whom the personal information was disclosed for a business purpose.
• The specific pieces of personal information we have collected about you.
• Our business or commercial purposes for collecting that personal information.
• If we disclosed your personal information for a business purpose, we will list such disclosures, identifying the personal information categories that each category of recipient obtained.
The Right To Request Deletion
You may have the right to request that we delete any of your personal information that we collected from you and retained. Once we receive and confirm a verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny a deletion request if retaining the information is necessary for us or our service providers to:
• Complete the transaction for which the personal information was collected; provide a good or service requested by the California Consumer or reasonably anticipated within the context of a business's ongoing business relationship with the California Consumer or otherwise perform a contract between the business and the California Consumer.
• Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses' deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
• To enable solely-internal uses that are reasonably aligned with the expectations of the consumer based on the consumer's relationship with the business.
• Comply with a legal obligation
• Otherwise use the California Consumer's personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Exercising the Right To Know and the Right To Request Deletion
• To exercise the right to know and the right to request deletion, please submit a verifiable consumer request to us by contacting the in-Service customer service “Contact support”.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
We are required to respond to your verifiable consumer request no more than twice in a 12-month period. The verifiable consumer request must:
• Provide sufficient information—for example, your name, address, or other information depending on the type of request and the sensitivity of the information requested—that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative; and
• Contain sufficient detail such that we are able to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and cannot confirm that the personal information belongs to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We will respond to a verifiable consumer request within 45 days of its receipt when possible. If we require more time (up to 45 additional days), we will inform you in writing, within 45 days of receipt of the original request, of the extension period and the reason for the extension.
Any disclosures will cover only the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. we will deliver information by mail or electronically, at your election, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, readily-useable format that allows you to transmit the information to another entity without hindrance.
We do not charge a fee to respond or process your verifiable consumer request unless it is manifestly unfounded, excessive, or repetitive. In such a case, we may charge a reasonable fee or refuse to act on the request, but we will inform you of the reasons for that decision and provide you with a cost estimate before completing the request.
Non-Discrimination
We will not discriminate against you because you have exercised any of your rights under the CCPA, including, but not limited to, by:
• Denying products or services to you;
• Charging different prices or rates for products or services, including through the use of discounts or other benefits or imposing penalties;
• Providing a different level or quality of products or services to you; or
• Suggesting that you will receive a different price or rate for products or services or a different level or quality of products or services.
Removal of Publicly Posted Content
Any California residents under the age of 18 who have registered to use the Service, and who have posted content to a publicly available portion of the Service, can request that such information be removed from the Service by contacting us at the e-mail or address set forth below under “Contact Information”. Such request must state that they personally posted such content and detail where the content is posted and in some cases, we may ask questions to verify your identity. We will make reasonable good faith efforts to remove the content from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished the information and archived copies of it may be stored by search engines and others that we do not control.
For users that are located in the European Economic Area:
You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us through the in-Service customer service “Contact support”.
Access
You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us and complete the corresponding request form.
Portability
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you as described in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
Correction
You have the right to correct any personal information held about you that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us and complete the request form.
Erasure
You can delete your account, or remove certain personal information. If there is any other personal information you believe we process that you would like us to erase, please contact us and complete the request form.
You may request that we erase the personal information we hold about you in the following circumstances:
• you believe that it is no longer necessary for us to hold such personal information; or
• you believe the personal information we hold about you is being unlawfully processed by us.
You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.
We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
You may request we stop processing and just store the personal information we hold about you where:
• you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;
• you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead; or
• you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defense of legal claims.
Objection
You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by contact us and completing the request form.
Announcements
We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Services access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
If you have any questions about this Policy, or if you have any further queries, please contact us through the in-Service customer service“Contact support”.
For the purposes of European Data Protection Law, the Data Controller is GEARUP PORTAL PTE. LTD.
In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance.
If we make any material changes to this policy, we will post the updated policy here and notify our users. Please check this page frequently to see any updates or changes to this policy.
This Agreement may be translated into the local language in the relevant territory. In the event of a conflict between this Agreement in the English language version and the localized version, the English language version shall prevail.