Your Privacy Matters to Us JOYCITY and its affiliates ("JOYCITY ", “us”, “our” or "we") are dedicated to protecting the privacy rights of our users ("users" or "you"). This Privacy Policy (the “Policy”) describes the ways we collect, store, use, and manage the information, including personal information, that you provide or we collect in connection with our websites, including www.joycity.com (the “Sites”) or any JOYCITY game provided on a console platform (collectively, the "Service"). Please note that the scope of this Policy is limited to information collected or received by JOYCITY through your use of the Service. JOYCITY is not responsible for the actions of third party people or companies, the content of their sites, the use of information you provide to them or any products or services they may offer. By using the Service, you are expressing your agreement to this Policy and the processing of your data, including your personal information, in the manner provided in this Policy. If you do not agree to these terms, please do not use the Service. This Privacy Policy will provide you with information on our policies regarding: 　 1. How and What information is collected 2. Who Collects Your Information 3. How We Use Your Information 4. Sharing of Your Information 5. Protection of children’s information 6. Your Choices 7. Security of Your Information 8. Do not track signals (California Online Privacy Protection Act) 9. International Transfer 10. Information for people in the European Union 11. Changes to Privacy Policy 12. General 13. Contact Us 1. How and what information is collected JOYCITY collects information as described below. JOYCITY’s primary goals in collecting and using information is to create your account, provide Services to you, improve our Service, contact you, conduct research and create reports for internal use. We store information on servers located in many other countries and may store information on servers and equipment in countries other than where you are from Web site While you are browsing JOYCITY's Sites, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language and referring Web site addresses may be logged automatically. We may use this information to monitor and analyze your use of the Service. In addition, we may ask you to submit and we may process data that is personal to you, including but not limited to your name, profile photo, gender, age or birthday, links to your profiles on social networking websites and other third party sites, user names and e-mail and mail addresses. We may use this information to create a user profile. We may use your email address to contact you about your experience with JOYCITY Sites and notify you about company news and promotions. Your gender and birthday may be used to analyze user trends and target certain promotions. Your mail address may be used if we have merchandise or other physical promotional materials that we want to send to you. Forums JOYCITY may at times offer you the ability to post content to a blog, message board, chat room or within JOYCITY’s applications or other forums such as JOYCITY’s Facebook page (“Forums"). You should be aware that any visitor to the Forums may read your postings on the Forums. Furthermore, any information that you may post to a Forum, including your username or other account profile information, will be disclosed and available to all users and viewers of that Forum, and will therefore no longer be private. JOYCITY cannot guarantee the security of such information that is disclosed or communicated online in public areas such as the Forums, and you provide such information at your own risk. You acknowledge and agree that JOYCITY has no responsibility for the accuracy or availability of information provided on any Forum. JOYCITY reserves the right at any time, in its sole discretion, to remove any content that a user may post on any Forum and restrict their access to any Forum. Console Platforms When you use any of the JOYCITY games or applications on a console platform, we may collect and record certain information such as your unique device ID (persistent / non-persistent), hardware type, the version of your operating system (“OS”), your device name, and your location (based on your Internet Protocol (“IP”) address). This information is useful to us for troubleshooting and helps us understand usage trends. In addition, we create a unique user ID to track your use of our Service. This unique user ID is stored in connection with your profile information to track the JOYCITY games you are playing. Customer Service We may collect your email address when you contact our customer service group and we may use that email address to contact you about your gaming experience with JOYCITY games and notify you about company news and promotions. Game Data Collection Whenever you play our games, we collect data about all of your interactions with the game and with the other players inside the game via server log files. Other Collection We may also acquire information from you through (a) your access and participation in message boards on the Service, (b) your participation in surveys regarding the Service or (c) your participation in a sweepstakes or contest through the Service. Cookies A cookie is a small text file that we transfer to your computer and/or device, to identify a user's computer/device and to "remember" things about your visit, such as your preferences or a user name and password. Information contained in a cookie may be linked to your personal information for purposes such as improving the quality of our Service, tailoring recommendations to your interests, and making the Service easier to use. 2. Who Collects Your Information JOYCITY owns and operates the Sites, and is the company that collects Personal Information on our site. Our mailing address is JOYCITY Corporation, First Tower 11F, Bundang-ro 55, Bundang-gu, Seongnam-shi, Gyeonggi-do, Republic of Korea and our customer service email address is privacy@joycity.com 3. How We Use Your Information We use information collected through our Service for purposes described in this Policy or disclosed to you in connection with our Service. For example, we may use your information to: • create game accounts and allow users to play our games; • identify and suggest connections with other JOYCITY users; • operate and improve our Service; • understand you and your preferences to enhance your experience and enjoyment using our Service; • respond to your comments and questions and provide customer service; • provide and deliver products and services you request; • send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; • communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by JOYCITY and our selected partners; • enable you to communicate with other users; and • link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services. 4. Sharing of Your Information It is our policy not to share the information about you with third parties except with commissioned data processors of JOYCITY. We may share your information with the below stated commissioned data processors for certain purposes, including for the purpose of explaining our user demographics or improving the quality or delivery of our Services or providing platform services or for providing you with proper functioning of the Services. Although we will not share the information about you with third parties for the purpose of enabling third parties to send marketing materials to you about their products or the products of others, we may use third party advertisers to deliver advertising within the JOYCITY Servicing environment. Please be informed that JOYCITY and Third Party Platform Provider reserves the right to contact you at any time using the information about you for administrative or billing-related issues. If you do not want us to share the information about you with the third parties set forth below for particular purposes as described, please see Section 6 below, “Your Choices”, or do not provide us any information about you or use our Services. • With your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies. • JOYCITY may engage other companies and individuals to perform services on our behalf including but limited to analyzing data. These agents and service providers may have access to your personal information in connection with the performance of services for JOYCITY. • We may release your information as permitted by law or when we believe that release is appropriate to comply with the law; enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. • JOYCITY may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. • We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties. 5. Protection of children’s information Information for Parents/Guardians If you are a parent or guardian who has discovered that your child has submitted his or her personal information without your permission or consent, JOYCITY will take reasonable steps to remove that information from our database at your request. To request removal of your child's information, please send us an email at privacy@joycity.com and be sure to include in your message the same user name, password, and email address that your child submitted. If your child has used your credit card on our Sites without your permission, contact us immediately at privacy@joycity.com California Minors We provide registered users the ability to post information on our Sites. If you are a California resident who is under 18 and a registered user of our Sites and you are unable to remove content or information you posted in a public area of the Sites following the instructions provided on the Sites, you may request removal by using the contact information provided at the bottom of this Privacy Policy. When requesting removal you must be specific about the information or content you want remove and provide the URL for each page on the Site where it is located so that we can locate it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain the content or information; (2) the content or information was not posted by you the registered user; (3) we anonymize the content or information so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information. 6. Your Choices You may at any time indicate that you wish us to stop processing the information about you (if such information is necessary for you to have an account, you will no longer be able to use the Services and may no longer be able to use other aspects of the Service). You may also at any time ”opt out” of receiving materials described in this Privacy Policy from us and/or our commissioned data processors. The materials that we send you (e.g., e-mails) will indicate that such materials are from us and will always provide you with a method of “opting out” of receiving future materials of a similar nature. If you do not ”opt out” of receiving such materials, this will signify your continuing consent to JOYCITY using your information to continue to provide you with such materials and otherwise share the information about you with or transferring it to our commissioned data processors who provide products or services (or advertisements, marketing materials or other information) that we believe may be of interest to you. If you decide that you would like to ”opt-out” of receiving such materials from JOYCITY, please edit your account information on our Site or Game accordingly. If, at any time after you have provided us with such information, you decide that you would like to “opt-out” of JOYCITY providing it to its commissioned data processors, please contact us immediately at privacy@joycity.com. Keep in mind that, while JOYCITY encourages its commissioned data processors, to adhere to our policies regarding the privacy of our users and otherwise to handle the information about you in a responsible manner, we cannot and do not assume any responsibility for any actions or omissions of third parties, including the manner in which they use information received either from us or independently. 7. Security of Your Information JOYCITY takes reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. 8. Do not track signals (California Online Privacy Protection Act) (1) JOYCITY does not use or respond to "do not track" signals. Even if you select “Do Not Track” options provided by your browser, our Sites will still attempt to, and may be successful at, placing cookies, tracking identifiers, or other recording tools and collecting information from your browser. You may still manage the settings on your browser or mobile device and delete and disable cookies and other tracking/recording tools. Doing so may impact your experience using our Sites and may make certain features and areas unavailable to you. We do not control tracking by third parties providers. (2) JOYCITY does not sell or share Personal Information from JOYCITY players with third parties for those third parties’ direct marketing purposes. California Civil Code Section 1798.83 permits California residents to request information from us concerning any disclosures of Personal Information we may have made in the prior calendar year to third parties for direct marketing purposes. If you are a California resident and you wish to request information about our compliance with this law or our privacy practices, you may contact us by using the contact information at the bottom of this Privacy Policy. 9. International Transfer JOYCITY is based in Republic of Korea, and the information we and our Service Providers collect may be disclosed or transferred to JOYCITY, agents or third parties authorized to act on our behalf and such information is governed by South Korea law. You consent to the transfer, processing, storage, and use of your information in Republic of Korea. For information of users based within the European Union, such transfers of personal information shall be based on the implementation of the EU’s standard Model Clauses where the transfer is outside of the European Economic Area or not to a country to which an adequacy decision applies. At the date of this Privacy Policy, there is no adequacy decision in relation to Korea by the European Commission. At places where the personal information is transmitted, retained or processed, we take reasonable measures for protecting personal information which is in its possession or under its control against any unauthorized or accidental disclosure, access or deletion. 10. Information for people in the European Union By consenting to this Privacy Policy, you confirm that your command and knowledge of English (or in some cases, French or German) is sufficient to understand the terms and conditions set forth herein. For persons in European Union countries, as used in this Privacy Policy, terms such as "personal information" refer to "personal data" as defined by the UK Data Protection Act 1998 ("Act"). The terms "data controller" and "data processor" shall also be as defined in the Act. We will not collect any personal data from you unless you provide it voluntarily by providing us with your freely given specific and informed consent. By using JOYCITY websites (including, without limitation, the Sites) or services, you agree that we may transfer your personal information outside the European Union in connection with the purposes stated in this Privacy Policy. Your personal data may be transferred to the Republic of Korea(and/or other non-EU jurisdictions, as applicable). If You are ordinarily resident in the European Union any reference to an age of 13 in shall be deemed a reference to the age in your home country, below which, children receive additional legal data protections afforded to younger minors. 11. Changes to Privacy Policy JOYCITY reserves the right to change, modify, add or remove portions of this Privacy Policy. When we decide to change, modify, add or remove portions of this Privacy Policy, we may notify you via postings on our Services. If the changes are material, we may notify you via email (through the email address you have provided in your JOYCITY account) before the changes go into effect. Please ensure that you keep up to date with any changes by visiting this page on a regular basis. 12. General Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consents that you had provided to us with regard to processing of your personal information. For the avoidance of doubt, in the event that relevant personal information protection laws permit an organization such as us to collect, use or disclose your personal information without your consent, such permission granted by the laws shall continue to apply. 13. Contact Us If you have any questions or comments regarding our Privacy Policy or wish to access personal information collected by us, please contact us at privacy@joycity.com or send us a letter to the address below. JOYCITY Corporation Attention:Chief Privacy Officer Han Seo Jo Address: First Tower 11F, Bundang-ro 55, Bundang-gu, Seongnam-shi, Gyeonggi-do, Republic of Korea Last Updated on August 29, 2018