Privacy Policy

Effective date : 31 August, 2020

Clover Games is a game development company specialized in the mobile games. We create and publish mobile games and applications that aim to entertain and enjoy. We understand there's a lot of responsibility in handling that personal information which is why we have a policy that explains how we collect, store, use, and manage the information you provide or we collect in connection with our mobile game. This privacy policy provided below applies and reflects the enhanced transparency requirements of the EU General Data Protection Regulation.

Who is the controller & processor?

Clover Games(hereinafter also "we", "us"), which is a game development company with offices in Gangnam-gu, Seoul, Republic of Korea, wishes to inform you below how your personal data are processed within the context of using our mobile game service through the mobile application(hereinafter also "Service").

Whom can I contact?

If you have any further queries regarding data protection in connection with our Service offered, please send requests for information to:

Name of the controller: Lim Jong-Hwui (DPO of Clover Games)
Address: 7, Teheran-ro 5-gil, Gangnam-gu, Seoul, Republic of Korea
Attention: Privacy
email: privacy@clovergames.zendesk.com

Which personal data do we collect?

The categories of personal data we collect depends on the part of the Services you use and the requirements of applicable law.

When you use our Services, we collect the data as follow:

  • Your internet protocol ("IP") address
  • Application store you use
  • Mobile operating system type and version
  • Your mobile device model
  • Timezone setting of your mobile device
  • Country and and language setting of your device
  • Access token data when you connect our service through your other platform's account, such as Facebook access token, Google Play access token, Apple ID access token, and LINE ID access token
  • Device token data(UUID) made when you using our Service
  • Data about your use of the Service, such as your gameplay data
  • Your birthday

When you contact us directly for the customer services, we collect the data as follow:

  • Your nickname when using our Service
  • Your email address
  • Mobile operating system type and version
  • Your mobile device model
  • Your inquiry

Why do we process your data (purpose of the processing) and what is the legal basis?

We process your data based on your consent pursuant to Art. 6(1), Subparagraph. 1(a) GDPR for the purposes below:

  • to create your account and enable us to make our mobile game processed and operate for you
  • to respond the question that you request as a customer service so that we can provide you a better experience with our Service

Legal basis – Our information collection for the above purposes is necessary for performing the Service which you requested and supporting the delivery of customer services, see Article 6(1)(b) of the GDPR.

Any consent given can be withdrawn at any time. This also applies to the withdrawal of declarations of consent given to us before the GDPR came into force, in other words, prior to the effective date of this privacy policy. The withdrawal of consent is only effective for the future and does not affect the lawfulness of data processing up to the time of withdrawal.

How long are your data stored?

Your personal data will be deleted as soon as they are no longer necessary for the stated purposes herein.

Who receives your data & Why? (Sharing of information)

Clover Games does not share your personal data with third parties without your prior consent. In the context of the data processing for the purposes above, your data may be passed on to the following categories of recipients based on the legal bases under Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR. This personal data also will be deleted as soon as they are no longer necessary for the stated purposes herein.

In relation to storing personal data in the web cloud, we share Amazon Web Services, Inc. and Google LLC the following data of you

  • Your internet protocol ("IP") address
  • Application store you use
  • Mobile operating system type and version
  • Your mobile device model
  • Timezone setting of your mobile device
  • Country and and language setting of your device
  • Access token data when you connect our service through your other platform's account, such as Facebook access token, Google Play access token, Apple ID access token, and LINE ID access token
  • Data about your use of the Service, such as your gameplay data

The purpose of sharing this data is to store all of the information about our Service such as mobile game database, log database which is necessarily for providing our mobile game service.

In relation to log and operation managing, we share Ngle, Co. Ltd. and NHN Co., Ltd. the following data of you

To Ngle, Co. Ltd. ,

  • Your nickname when using our Service
  • Your email address
  • Mobile operating system type and version
  • Your mobile device model
  • Your inquiry

The purpose of sharing this data is to manage users of our mobile games and deal with the customer service request because Ngle, Co. Ltd. provides us the operating tool for accessing data on our Service.

To NHN Co., Ltd.,

  • Your internet protocol ("IP") address
  • Application store you use
  • Mobile operating system type and version
  • Your mobile device model
  • Timezone setting of your mobile device
  • Country and and language setting of your device
  • Access token data when you connect our service through your other platform's account, such as Facebook access token, Google Play access token, Apple ID access token, and LINE ID access token
  • Device token data(UUID) made when you using our Service

The purpose of sharing this data is to manage users of our mobile games and operate our Service because NHN Co., Ltd. provides game operating service to store and manage the information of your game play data.

In relation to providing the customer service, we share Zendesk, Inc the following data of you

  • Your nickname when using our Service
  • Your email address
  • Mobile operating system type and version
  • Your mobile device model
  • Your inquiry

The purpose of sharing this data is to respond to your customer service requests because Zendesk, Inc provides us the management tool about customer service. We only share this information under the purpose of dealing the customer service issue.

What are your data protection rights?

We are committed to ensuring fair and transparent processing. That is why it is important to us that data subjects can not only exercise their right to object but also the following rights where the respective legal requirements are satisfied:

  • Right of access, Art. 15 GDPR
  • Right to rectification, Art. 16 GDPR
  • Right to erasure ("right to be forgotten"), Art. 17 GDPR
  • Right to restriction of processing, Art. 18 GDPR
  • Right to data portability, Art. 20 GDPR
  • Right to object, Art. 21 GDPR

To exercise your right, please email privacy@clovergames.zendesk.com

Please provide the following details so that we can identify you:

  • Nickname in our mobile game
  • E-mail address

In order to be able to process your request, as well as for identification purposes, please note that we will use your personal data in accordance with Art. 6 para. 1 (c) of the GDPR. You also have the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR in combination with Section 19 GDPR.

How can you withdraw your consent?

If you consent to us processing your personal data, please note that you may withdraw this consent at any time. Please send us the e-mail(privacy@clovergames.zendesk.com) with your nickname in order to withdraw original consent in the settings.

Please note that your consent can only be withdrawn with future effect and such a withdrawal does not have any influence on the lawfulness of past processing. In some cases, we may be entitled in spite of your withdrawal to continue to process your personal data on a different legal basis – to perform a contract, for example.

What data do we process when you visit our website?

Our website uses cookies. Cookies are small text files placed by a web portal on the computer systems (computer, tablet or smartphone) of the users that visit it. Cookies may store personal data. You can prevent tracking via cookies (do not track, tracking protection list) and reject the storage of third-party cookies by not clicking 'accept' button at our website's consent dialog and by changing your browser settings. If you delete all cookies, this will also delete any opt-out cookies placed, so you will have to actively opt-out again.

We want you to be in a position to make an informed decision for or against the use of cookies which are not absolutely necessary for the website's technical features.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are a resident. Specifically, our storage web cloud servers are located in United States (Google cloud platform provided by Google LLC) and Japan (Amazon Web Service provided by Amazon Web Service, Inc). In addition, our cooperation partner's servers(NHN Co., Ltd., Ngle Co, Ltd. , Zendesk, Inc.) are located in Korea. This means that when we collect your personal information, we may process it in any of these countries.

  • Concerning our storage web cloud servers, when transferring your data out of the country we may not request your consent separately by following reasons:

Google Cloud Platform provided by Google LLC already gained confirmation of compliance from European Data Protection Authorities for our model contract clauses affirming that their contractual commitments for Google Cloud Platform fully meet the requirements to legally frame transfers of personal data from the EU to the rest of the world.

Amazon Web Service provided by Amazon Web Service, Inc.'s storage server is located in Japan where the country had acquired an adequacy decision by GDPR.

  • Concerning transfer other countries by using the storage service provided by NHN Co., Ltd., Ngle Co, Ltd. and Zendesk, Inc. to manage user's game data and respond the customer service requested, we ensure that we will get your explicit consent separately with our purpose of transfer, whom your data transferred by, which of your data transfer. Clover Games will not transfer this personal data out of your country without your prior consent. Also, this personal will be under the equivalent level of protection with our appropriate safeguards.

How do we protect your data?

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

Policy regarding children

Under GDPR, if you are in the EU and under the age of 16, in order for you to use our games you must receive consent or authorization from someone who holds parental responsibility for you. We will make reasonable efforts to verify in such cases that consent is given or authorized by the holder of parental responsibility.

We do not knowingly collect or solicit personal information from anyone under the age of 16. No one under the age of 16 may provide any personal information without parental responsibility. In the event that we learn that we have collected personal information from a child under age 16 without the consent of their parent, we will delete that information as quickly as possible.

For California Residents

The following section applies to only to residents of California.

  • Data Collection

The categories of personal data we have collected in the preceding 12 months, and the sources of the data, are described in the section "Which personal data do we collect" in this privacy policy.

  • Data Use

The business or commercial purposes for collecting your personal data are described in the section "Why do we process your data (purpose of the processing) and what is the legal basis?" in this privacy policy.

  • Data Disclosure and Sale

We do not "sell" your personal data with third parties as most people would understand that term. However, we may share your personal data with our third-party data storing service providers to operate and manage the Service we provided to you. To the extent that practice is considered a "sale" under the CCPA, you may opt out of the sharing by requesting opt-out to us via contact information in this privacy policy.

We do not have actual knowledge of any sale of personal data of minors under 16 years of age, as the term "sale" is defined under the CCPA.

In the preceding 12 months, we have disclosed the following categories of personal data as part of our Services:

Category of Personal Data Collected Examples of Data Collected Categories Of Third Parties Who May Receive Personal Data For A Business Purpose
Identifiers IP address, Facebook access token, Google Play access token, Apple ID access token, and LINE ID access token, Device token data(UUID) Amazon Web Services, Inc., Google LLC, Ngle, Co. Ltd., NHN Co., Ltd.
Device Information and Game Data Application store you use, Mobile operating system type and version, Your mobile device model, Timezone setting of your mobile device, Country and and language setting of your device, Data about your use of the Service, such as your gameplay data Amazon Web Services, Inc., Google LLC, Ngle, Co. Ltd., NHN Co., Ltd.
Inquiry Data Nickname, e-mail address, Mobile operating system type and version, Your mobile device model, Your inquiry Zendesk, Inc.

In addition to the sharing described above, we may share any information we collect about you with our affiliates, to protect us or others, or in the event of a merger, sale, or other asset transfer. See the section "Who receives your data & Why? (Sharing of information)" in this privacy policy for more information.

  • Your Rights

Right to Request Access to Your Personal Information : California residents have the right to request, up to two times in a 12-month period, that we disclose the categories of your personal information we collect, use, and share. You may also request the specific pieces of personal information that we have collected from you. Please note that certain information may be exempt from such requests under California law.

Right to Request Deletion of Your Personal Information : You may also request that we delete personal information that we collected from you. Some information may be exempt from such requests under California law. For example, we need certain types of information so that we can provide our Service to you. If you ask us to delete it, you may no longer be able to access or use our Service.

How to Exercise Your Access and Deletion Rights : California residents may exercise their California privacy rights by submitting your request to us here or sending an email to privacy@clovergames.zendesk.com.

For security purposes, we will verify your identity – including requesting information from you – when you request to exercise your California privacy rights. If you have an online account you use to interact with us, logging into your account will serve to verify your identity and request. We may request additional information if we believe your account has been compromised. If you do not have an account with us, or if we have reason to suspect that the security of your account is compromised, then we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.

Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate. If we are unable to complete your requests, we will provide you information about the reasons that we could not comply with your request.

Right to Nondiscrimination : We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

Related articles