PRIVACY POLICY

Gravity Game Hub (GGH) PTE LTD. (“Company,” “we”, “us” or “our”) maintains this Privacy Policy (“Privacy Policy”) that summarizes our policies and processes on how we collect, use, disclose, transfer and store your personal information. The Privacy Policy applies only to the collection, use and storage of personal information that you, EXCLUDING a European User (defined as hereinafter), may decide to provide to us in your use of: (1) our website(s) (our “Sites”), (2) our application named Ragnarok X: Next Generation as an Mobile game which can be played by End Users on a feature phone, smart phone, PDA, tablet computer, portable media player or other handled devices (“Mobile Devices”) and is operated in certain hardware environment with such operating system (“Markets”), includes, without limitation, Android, IOS and Windows phone (the “Application”), and (3) chat rooms, blogs, web forums, messaging boards or other public forums in Application and our Sites (collectively, our “Forums”). The Application, Sites and Forums are referred to herein collectively, as the “Services”. For the purpose of clarity, the Mobile game named Ragnarok X: Next Generation is not HTML5 game which is is developed based on HTML5 language to enable you to play Ragnarok X: Next Generation on smartphone over the internet using a web browser as well as on computer over the internet using a web browser. By accepting our Privacy Policy and the applicable Terms of Service during Service account registration or by otherwise accessing or using our Service(s) you are agreeing to the terms and conditions of this Privacy Policy (including our collection, storage, use and disclosure of your personal information) and that your access or use of the Service(s) is also subject to the applicable Terms of Service. PLEASE NOTICE THAT COMPANY DO NOT PROVIDE ANY GAME SERVICE TO USER(S) IN THE TERRITORY OF EUROPEAN ECONOMIC AREA (EEA) WHICH INCLUDES THE EUROPEAN UNION MEMBER STATES AND ICELAND, LIECHTENSTEIN AND NORWAY (EUROPEAN USER). THEREFORE, PLEASE DO NOT ATTEMPT TO PLAY ANY GAME ON OR THROUGH ANY COMPANY’S SERVICES IF YOU ARE A EUROPEAN USER.

Collecting Personal Information

Use, Disclosure and Transfer

Unless otherwise described elsewhere in this Privacy Policy, we will not use or disclose any personal information collected from you. Your personal information may be used alone or in the aggregate with information collected from other users.

Use by Company

We use the information you provide so that we may better understand your needs and the needs of our customers, prospective customers, and visitors. Specifically, we use your personal information for many purposes, including:

(a) to allow you to register for and use our Services;

(b) to apply for employment opportunities at the Company;

(c) to audit and analyze data to improve and ensure the continued smooth operation of our Service;

(d) for market research purposes, including, without limitation, to analyze user characteristics and usage patterns in order to understand better how our Services are used and market them more effectively;

(e) to communicate with you concerning your account or to send you announcements, newsletters, promotional materials and other information about our Services or offerings of our business partners, and to offer you opportunities to participate in surveys, contest and sweepstakes;*

(f) to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving our Service;

(g) to respond to inquiries, troubleshoot problems, investigate incidents, and handle complaints;

(h) provide, maintain, protect and improve our Services, including keeping you posted on our latest Service announcements, software updates and upcoming events, and develop new services;

(i) protect our rights or property or that of our users;

(j) to satisfy any applicable law, regulation, legal process or enforceable government request;

(k) to send notices, such as communications about your purchases and changes to our Terms of Service, this Privacy Policy and other Service-specific policies, and to enforce applicable terms and conditions set forth in such policies;

(l) to enable user-to-user communications; and

(m) protect against harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.

The Company processes personal information on our databases, equipment and servers (owned by the Company and/or third parties in Singapore & South Korea and in other countries),provided that all such data processing activities involving servers deployed in the United States shall be exclusively conducted within the territory of the United States, in accordance with applicable data protection laws and regulations governing cross-border data transfers.

*If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or follow the process described in the “Opt-Out Provision” section below

Disclosure and Transfer to Third Parties

We generally do not disclose or transfer any personal information about our customers, prospects, or visitors to any third parties. We may however, disclose and transfer data which does not contain or reveal any personally identifiable information or is specifically attributable to you to our business partners, third party analytics service providers, ad networks and advertisers (collectively, “Partners”). Provided, however, some Partners may also act as third party service providers (described below) to us and may have access to your personally identifiable information. Moreover, Partners may obtain public information about you from your profile or other public sources.

We may also periodically engage in co-marketing activities, where we work with a complementary solution provider to launch a joint marketing program. In these situations, we will only send information to you on behalf of the other; we do not provide your personally identifiable information to such partner. We may also enter into business partnerships with other parties to provide specific services. If a user signs up for these services or responds to a particular marketing offer, we may share personally identifiable information such as your name or other contact information that is necessary for our business partner to provide these services or get in contact with you.

Disclosure of your personally identifiable information may occur when we engage or employ service providers, vendors or other third parties to facilitate the provision of our Services (including, without limitation, payment processing, data analysis, e-mail delivery, hosting services, customer service and promotional services) to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Such third party service provider ( “Third Party Partner”) may have access to your personally identifiable information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

In the event Company combines with another company in the future through a corporate merger, sale, acquisition, liquidation or other similar process, your personally identifiable information may be transferred with the business or a part of it, or may be sold as an asset of the business, to the successor organization in such transaction. If material changes to the Company’s privacy practices will occur as a result of such transaction, we will notify you and other users in the manner described in this Privacy Policy.

In addition, upon the expiration or the termination of any third party license arrangements involving one or more parts of the Service, your personal information (including name, email address and other personally identifiable information) may be transferred to the subject third party licensor in accordance with the terms of the applicable license agreement. In advance of such transfer to a third party licensor, the Company will notify you and other users in writing in the manner described in this Privacy Policy.

Safety, Security and Legally Required Disclosures

Your personally identifiable information, and communications you make within the Service, may be accessed and disclosed if we believe that our Service is being used in the commission of a crime, when we believe in good faith that there is an emergency that poses a threat to the safety of you or another person and when necessary either to protect our rights or property including to enforce our Terms of Service, or for us to render the service you have requested.

We may also disclose personally identifiable information when required by law, regulation, court order, or in response to a subpoena or litigation discovery request, or in the good faith belief that such action is necessary in order to conform to the edicts of the law or comply with a legal process served on us. In addition, we will make any legally required disclosures to government authorities and provide notice to you of any breach of security, confidentiality or unauthorized release of personal or private data in accordance with applicable laws, rules and regulations.

Storage and Security

We employ reasonable measures (both online and offline) to protect the security of information we collect from you. Such information is housed in secure databases, equipment and servers located in the United States. The databases, equipment and servers we utilize may be owned by third party providers. To prevent unauthorized access, loss, or misuse, maintain data accuracy, and ensure the appropriate use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we maintain. We use industry-standard technology, such as firewalls, in an effort to protect the confidentiality of your personal information. Moreover, in addition to password protection offered in connection with your Service account, we encrypt your transmission of sensitive information to us (e.g., account passwords and payment-related identifiable information) via SSL (secured socket layer) protocol in the interest of heightened privacy protection and information integrity.

Although we take reasonable precautions against possible security breaches of our Service, databases, equipment or servers, and records, we cannot guarantee that unauthorized access, hacking, data loss, or other security breaches and factors beyond our control will never take place and result in disclosure of your personal information. Accordingly, we disclaim any guarantees, warranties or representations relating to maintenance or nondisclosure of any personal information collected from you. We strongly urge you to take reasonable measures at all times (online and offline) to protect your personal information, including your password and other sensitive information..

In addition, while we strive to protect your personal information, you should know that information sent over the Internet, whether by e-mail or by using one of our on-line forms, is not necessarily secure against interception. Therefore, we cannot be responsible for such interception and cannot guarantee the security of such information..

We will investigate, attempt to resolve and take all reasonable steps necessary to ensure that your personal information and data is treated securely and in accordance with this Privacy Policy..

We will retain your personal information for as long as is necessary to fulfill the purposes for which it was collected or as needed to provide you with Services. We may retain your personal information after you have closed any account you have with us or after we have ceased providing Services to you if retention of your Personal Information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between members, prevent fraud, cheating or abuse, or enforce this Privacy Policy or any other agreement we may have with a user.

Additional Privacy Policy Terms

California Residents

The California Consumer Privacy Act or “CCPA” provides consumers residing in California certain rights with respect to their personal information. If you are a California resident, you may have the right to:

(i) request to know more about the categories and specific pieces ofpersonal information we collect, use, and disclose;

(ii) request deletion of your personal information;

(iii) opt out of sale of your personal information (if any); and

(iv) not be discriminated against for exercising these rights.

You or your authorized agent may make these requests by contacting us as described in this chapter. Note that we may ask you for additional information to help us verify who you are before completing your request. If we receive your request from an authorized agent, we may ask for evidence that you gave that person authority to submit requests to exercise rights on your behalf. We will not discriminate against you if you exercise your rights under the CCPA. We collect the following categories of personal information, as described in the CCPA:

(i)Identifiers (such as email addresses);

(ii)Demographic information (like ages);

(iii)Commercial information (including entitlements or purchase history); (iv)Internet or electronic network activity (for example, gameplay or website usage details);

(v)Audio, electronic, visual, or similar information (like voice chat);

(vi)Geolocation information (such as may be derived from your IP address or included in your billing information);

(vii)Other “personal information” as defined under California law (like your credit or debit card information); and

(viii)Inferences drawn from any of these categories (for example, about the genres of games you may prefer to play based on your purchase history).

For details about the precise data points we collect and the categories of sources where we got that information, please see “chapter2 Collecting Personal Information” above. We collect personal information for the business and commercial purposes described in “chapter3 Use, Disclosure and Transfer” above.

We does not sell or share (as those are defined in the CCPA) the personal information we collect. We do, however, disclose personal

information as described in this policy (see “chapter3 Use, Disclosure and Transfer” above). In the past 12 months, we have disclosed personal

information to the following categories of recipients:

(i)Business partners (for example, if you request that we share your email address with the developer of a game you purchase on the game store);

(ii)Other associate entities (like to subsidiaries that may help support certain our services);

(iii)Other users (for example, if you use chat or social features in our service);

(iv)Service providers (as described in “chapter3 Use, Disclosure and Transfer” above);

(v)Operating systems and platforms; and

(vi)Government entities or other third parties in response to a legal request.

Opt-Out Provision

When we first collect information from you, we will offer you the opportunity to opt-out of having your personal information shared with parties outside of Company (unless otherwise described in this Privacy Policy). In addition, if you do not want us to send you communications relating to our Services, including, without limitation, announcements, newsletters and promotional materials or offers to participate in surveys, contests or sweepstakes, you can opt-out at the time of registration or information collection. If, at a later date, you choose to have your name or any other personal information removed from our mailing list, you can do so by emailing support@gravitygamehub.com.

Review, Update, Correct, or Delete Personal Information

Generally, you may review, update, correct or delete your personal information collected by or through our Service by logging into your account. You may also correct factual inaccuracies. Certain types of personal information that is necessary to check eligibility, such as birth date or age, cannot be deleted, but may be modified with sufficient verification of the new information. Note that we reserve the right to terminate or delete any registration or promotional entry if we believe the personal information submitted was knowingly false or fraudulent.

To delete your personal information, you may also email us at support@gravitygamehub.com. We will use commercially reasonable efforts to honor your request.

Please be aware that even after your account is terminated or deleted, some or all of your information may still remain visible to others, including but not limited to any information that has been: (i) incorporated into others user’s content, comments, postings, submissions, cities, resources or other in-game assets; (ii) copied, stored or disseminated by other users; (iii) shared or disseminated by you or others such as in a public posting; or (iv) posted on a third party platform. A request to delete and/or termination of your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us. We are not able and/or obligated to remove any of your information from a third party platform.

Moreover, please be aware that even after you delete your account or your account is terminated, your information is not deleted in its entirety from our servers and may not be deleted from servers of the third party platform you use to access our Services. We may, but are not obligated to, retain backup copies of your information, including personal information on our servers or databases (and/or any authorized third party servers or databases we use). Such information may be disclosed pursuant to this Privacy Policy regardless of whether your account is deleted or terminated. Moreover, any third party platform that you use to access the Services may also retain backup copies of your information even after your account is deleted or terminated which may be used and/or disclosed in accordance with their privacy policy.

To have access to your personal information, you must provide proof of identification such as full name, street address, city/state and zip code, user ID and password, and/or information about your recent activity on our Service. We reserve the right to deny access to any user if we believe there is a question about your identity. And if the burden or expense of providing access to your personal information is disproportionate to the risks to your privacy, or if the legitimate rights of others would be violated, we may decide not to provide access to such information. Moreover, we may still retain an archived copy of your information in our files as required by law or for legitimate business purposes, including, resolving disputes, enforcing the Terms of Service, and for other technical and legal requirements and constraints related to our Service.

To manage the information we receive about you from the SNS where you play our games, you will need to follow the instructions at that SNS for updating your information and changing your privacy settings.

Notification of Changes

We reserve the right to update and change the terms of this Privacy Policy at any time. If we decide to update and materially change the terms of our Privacy Policy, we will post those changes in our Services and/or on the applicable Sites, and in the updated Privacy Policy. You should periodically check this Privacy Policy for updates.

By continuing to access or use the Services after we have posted an updated Privacy Policy or have provided you with notice of a modification, you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.

Links to Third Party Websites, Services and Offers.

Our Service may contain links to other websites, services and/or offers from third parties. We are not responsible for, nor will it be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information you voluntarily chose to provide to them. You should review the applicable privacy policies and information practices of such third parties carefully before providing personal information to them. Moreover, if you have any questions or concerns, you should contact the third party directly.

Protection of Children’s Privacy

Children who reach the age (“Competent Age”) to give valid consent under his/her relevant national law or who does not reach the Competent Age but gets valid consent from their legal representative (e.g. parents) can only use the application. We make reasonable efforts to verify if consent from or any contract concluded with such children is valid by offering users age verification methods and by obtaining clear consent from children’s legal representatives. If we learn that we have inadvertently gathered Personal Data from such children, we will take reasonable measures to promptly erase such information from our records. If children under Competent Age or their legal representative ask us to cease processing or profiling of the child’s Personal Data for the purposes of direct marketing, we will immediately do so.

We collect a parent or guardian email address from a child player in order to send the parent or guardian an email notice that the child has created a Cabined Account. This notice also lets them review our privacy practices for non-Cabined Accounts, provide consent to a non-Cabined Account for their child to enable additional features, and set up Parental Controls. Please note that parents/guardians must complete our parent verification process in order to provide consent to a non-Cabined Account.

Special Note to Parents

If you become aware that your child has provided us with personal information at our Service, we invite you to notify us so that we may delete the information from our records and discontinue any related features or services (see Opt-Out Provision above). We also urge parents to instruct their children never to give out their real names, addresses or phone numbers without parental permission when using the Internet. We appreciate your cooperation in assisting us to provide a safe and enjoyable online experience for your children.

Users Outside Singapore

The Company is a Singapore company and Company’s business operations are primarily conducted in Singapore. We operate our company and administer this Privacy Policy under applicable laws and regulations of Singapore. If you use our Service from outside Singapore, you are thereby consenting for your personal information to be transferred to, stored in and be processed in Singapore, South Korea and/or in other countries by the Company and/or its Affiliates in the manner described in this Privacy Policy. Your consent to this Privacy Policy followed by your submission of your personal information represents your agreement to transfer, storage and processing of information.

As described elsewhere in this Privacy Policy, when you submit personal information via our Service, the information is housed in secure databases, equipment and servers located in the United States. The databases, equipment and servers we utilize may be owned by third party providers.

Users in certain jurisdictions such as California may have a right to access his/her personal information held by the Company and/or its Affiliates. Your right of access to such personal information can be exercised in accordance with applicable laws, rules and regulations.

Company officially notifies that Company does not provide any Services to a European User. If you are a European User, please do not attempt to access Services or to play any game on or through any service of Company. Further, if you newly acquire the nationality, or at any reason at all, by which you become a European User after your using Services, you should notify such fact to Company for our terminating your access to the Services under the condition of the relevant TERMS OF SERVICE or this Privacy Policy.

Please submit any requests for such access to support@gravitygamehub.com.

Language

The controlling language of this Privacy Policy is English. If you have received a translation into any other language, it has been provided for your convenience only. The English version of this Privacy Policy shall govern to the extent of any inconsistency between the English version and any translated version.

Contact Us

If you have any questions, inquiries, requests, complaints, or comments regarding this Privacy Policy, or have other questions or suggestions about our information practices, please contact us via e-mail at support@gravitygamehub.com.