Undawn (Closed Beta Testing)

Recruitment Website (Canada and the United States)

https://www.undawn.game/en/cbt

Privacy Policy

Last Updated: 17 March 2023

Welcome to the Recruitment Website for the Undawn Closed Beta Testing!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information when you register your interest to participate in the Undawn Closed Beta Testing (“CBT”) through the Undawn CBT recruitment website (“Recruitment Website”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not submit your details through the Recruitment Website. By submitting your details through the Recruitment Website you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

This Recruitment Website has been developed by Proxima Beta Pte. Limited (“we”, “us”, “our”). For the purpose of data protection laws, the data controller of your personal information in relation to the Recruitment Website is Proxima Beta Pte. Limited. The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore.  

Please reach out to us if you have any questions or concerns regarding the processing of your personal information, or if you want to exercise any rights you may have. You can contact us anytime at dpo_undawn@proximabeta.com. 

1. Children

Children must not use the Recruitment Website for any purpose.

By children, we mean users under the age of 13 years old.

We do not knowingly collect personal information from children under this age for any purpose. If you believe that we have personal information of a child under this age, please contact us at dpo_undawn@proximabeta.com and we will delete such information.

2. Cookies

We use cookies and other similar technologies  (“Cookies”) to enhance your experience using the Recruitment Website. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.

For more information about our Cookies policy, click here.

3. How We Use Your Personal Information 

This section provides more detail on the types of personal information we collect from you, and why.

4. How We Store and Share Your Personal Information

For website information, we store your email address, device system version and IP address information in our servers with  Microsoft Azure in the United States, and other information is stored in Google Analytics’ server located in the United States.

For contact information, we store this with AIHelp’s servers in the United States.

For CBT registration information (via Amazon SES), we store this in our servers with Microsoft Azure in the United States, and with Amazon Web Services in the United States.

We also have support, engineering and other teams who may support the Recruitment Website, including from Singapore.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Third parties that provide services in support of the Recruitment Website (such as Google Analytics, AIHelp and Amazon SES), including to send you a link to sign up to the CBT. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

· Companies within our corporate group who process your personal information in order to operate the Recruitment Website. All such group companies may only use your personal information in accordance with this Privacy Policy.

· Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

· A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

5. The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Recruitment Website or otherwise via the Internet; any transmission is at your own risk.

6. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

7. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Recruitment Website. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you, such as access, correction, erasure, and objection rights. If you have any questions about or would like to exercise any of your rights, please contact us at dpo_undawn@proximabeta.com.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Recruitment Website 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.

Advertising

You may choose to stop receiving marketing related information from us when using the Recruitment Website by contacting us at dpo_undawn@proximabeta.com.

8. Contact

Please get in touch with us if you have any questions.

Email: dpo_undawn@proximabeta.com.

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

9. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Recruitment Website, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

· Identifiers, such as IP address, device ID, device token and email address. This information is collected directly from you and your device.

· IP address to provide you with the Recruitment Website.

We collect your personal information for the following purposes:

· To provide you with the Recruitment Website, select users to participate in the CBT, and to send emails  related to the CBT to you.

· If you subscribe to our marketing emails, we use this information to provide you with marketing news and promotional offers.

· To provide customer service.

For additional information about what each type of personal information is used for, see Section 3 How We Use Your Personal Information.

We disclose personal information to the following types of entities:

· Other companies within our corporate group who process your personal information in order to operate the Recruitment Website.

· Other companies that provide services on our behalf in support of the Recruitment Website and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.

· Regulators,  judicial authorities and law enforcement agencies.

· Entities that acquire all or substantially all of our business.

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

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 information about you that we collected;

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

o the purpose for collecting personal information about you;

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

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

· Request we delete personal information we collected from you, unless CCPA recognises an exception; and

· 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 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

First, 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_undawn@proximabeta.com.

Canada

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_undawn@proximabeta.com.  Where we use service providers who might have access to your personal information, 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 information and to prevent it from being used for any purpose other than as provided in this Privacy Policy. 

Virginia

This section applies to Virginia residents covered by the Virginia Consumer Data Protection Act (“VCDPA”). For purposes of this section, “personal data” and “sensitive personal data” have the meanings given in the VCDPA and do not include information excluded from the VCDPA’s scope.

If you are a Virginia resident and the law does not recognize an exception that applies to you or your personal data, you have the right to:

· request that we disclose to you the personal data that we collect, use, or disclose, and information about our data practices.

· request we delete personal data we collected from you, unless the law recognises an exception;

· request we correct inaccurate personal data that we maintain about you; and

· 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 law.

We do not collect sensitive personal data about you. We also do not process personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a Virginia resident to whom the VCDPA applies, you may also exercise your rights, if any, regarding other data by contacting us at dpo_undawn@proximabeta.com.

How to Appeal Decision on Your Request

If you would like to appeal a decision on your request to exercise any right you have under the VCDPA, you may contact us at dpo_undawn@proximabeta.com.