Privacy Policy

Date of effect and last updated date: 2022. 08. 18

[Display shortcut list]

1. Introduction to the Privacy Policy

‘ChuanQi IP’ (hereinafter referred to as 'Company') collects, uses, and processes data from users (hereinafter referred to as 'user', 'you'). The Company provides games, an official website, and game-related services (e.g.: events, surveys, customer support). This Privacy Policy gives an explanation of the personal data collected by the Company and the methods of use of said data, pertinent user rights, and methods through which users can communicate with the Company.
The Company may update the Privacy Policy at any time. Update information can be seen through the last updated date on the top. Continuing to use the Company's game, website, and game-related services after updates of the Privacy Policy signifies that you have agreed to the amended Privacy Policy. Users must periodically review this agreement to check details on the Company's processing of personal data from users. The Company can request confirmation of consent to this agreement during the service use process.

2. Data collected by the Company

The Company collects user information when the user accesses the Company's website, plays the games, or uses the Company's services. A portion of this data may be needed to confirm a contract with the user or to fulfill obligations according to contracts with users. (e.g.: provision of purchased content)

  1. 1) Data collected directly from users

    When a user plays the games or services, the Company collects the following data from users, and these data may differ according to the service used. These data are necessary for the usage of services and refusing data collection shall result in a limitation of the usage of services.

    1. a. User identification information from Google, Apple, and Facebook (*)
    2. b. Registration information such as name, phone number, and email address
    3. c. Transaction information such as purchase date and purchased items
    4. d. Demographic information such as date of birth or age, country of residence, language, and nationality
    5. e. Information disclosed when participating in social features (e.g.: in-game chat) is the information that was made public. The Company may save such information and other users may read, copy, collect or use them without the consent of the user.
    6. (*) When a user accesses the Company's services using an account for a platform, no information other than user identification information out of the information provided by each platform shall be collected or stored.
  2. 2) Automatically collected data

    The Company collects certain data automatically when a user plays the games or uses the services. The data automatically collected by the Company generally includes the following.

    1. a. IP address, MAC address, device model number, OS information, time zone settings, battery status, screen resolution, network type, device serial number, advertisement ID, device information including CPU, memory, storage, and VGA,
    2. b. game usage-related information including game settings, login records, transaction records and records of imposed restrictions,
    3. c. and browsing information such as browsing actions while the user uses the website and services.
    4. The Company uses these data to operate and improve its service. A portion of this data is collected through cookies and related online tools. For more details, please refer to the "Cookie-related Technology" section below.

3. Purpose of the Company using user data

The Company uses the collected data to provide games and services and for quality improvement.

  1. a. Managing and providing the Company's games and services
  2. b. Legal requirements, contracts, compliance with and enactment of policies
  3. c. Development of and quality improvement for new services and bug fixes
  4. d. Detecting and responding to the illegal or unauthorized use of the Company's games and services
  5. e. Responding to user inquiries and requests (e.g.: game-related inquiries etc.)
  6. f. Transmission of other information including marketing, events, and surveys
  7. g. Analysis of user patterns, use trends, and statistics on game and service usage
  8. h. Prevention, identification, investigation of, and responses to unlawful and criminal acts
  9. The Company may also process user data for compliance with relevant legal obligations and may seek approval from users when necessary, for the use of said user data. Users may withdraw their approval anytime through the contact channels listed in this policy.

4. Sharing user data

The Company shares personal data with other companies including service providers that process personal data as an agent for the Company in order to manage the services including customer support and community management for the purpose of providing the games and services.

  1. a. Managing and providing the Company's games and services

    For the provision of the services, the Company cooperates with certain service providers (e.g.: payment service providers, customer service companies that process user inquiries and requests, cloud storage service companies, and marketing platform providers), and these service providers may receive and process personal data according to the data processing contract signed following the Company's regulations, the process of providing corresponding services.

  2. b. Regulatory authorities

    The Company may disclose user data to the following authorities:

    1. - To regulatory authorities for data protection
    2. - Investigations by government organizations
    3. - Other regulatory authorities with jurisdiction over the Company's activities

    In addition, when such disclosures are mandatory for compliance with legal obligations following mergers and acquisitions or with legal data access requests, for the purposes explained in this policy statement, when the subsidiary companies or you have expressed exclusive consent or when data has been provided as per the request of the information principals, the Company may share the data.

5. The Company utilizes cookies and other technology to recognize users' browsers or devices, learn more about user preferences, provide core functions and services and provide to users for additional purposes. Authorized third parties may set up cookies and related technology when users use the sites or the games.

  1. a. Cookies

    Cookies are small files downloaded onto the computer to track movements within websites and define user experience within the said website (when the browser allows cookies). Most Internet browsers allow a warning to be sent before cookies are erased from the hard drive, permissions for cookies are blocked or cookies are saved. You must refer to the "Help" screen in the browser to learn the details of cookie management methods. However, disabling cookies may result in a part of the website not functioning normally. We do not control cookies in other Companies' advertisements and it is recommended that you check the Privacy Policy of the advertisement owner or the advertisement service provider to learn about the use of cookies and other technology. Advertisements displayed on the website can be transmitted to you by external advertising companies. These companies may use the information on the visits to this and other websites to provide advertisements to websites that feature goods and services you may be interested in, as well as other websites.

  2. b. Website analysis

    We use analytic services on this website to record the usage history of this website and to continuously improve the services. This website uses Google® Analytics, a web analytic service provided by Google Inc. (hereinafter referred to as "Google"). The Company uses the following advertising functions of Google Analytics, may collect personal data as provided by Google, and you may withdraw the consent to these by deactivating these functions in the Google advertisement settings. Remarketing using Google® Analytics; Google® display network exposure report; Google® Analytics demographical statistics and interest report; integrated services that allow the collection of data through Google® Analytics using advertisement cookies and anonymous IDs. You can view details on Google's Privacy Policy at If you intend to opt out of the information or data used by Google Analytics, you can download the Google Analytics opt-out browser add-on at

  3. c. Technology for the prevention of unlawful acts and fraud

    We strive to provide all users with a safe and fair service environment. When you use the services, for the purpose of preventing fraud and for security and authentication purposes, the Company or a third party may use cookies or similar technology or collect data on the machine or device used by users. Furthermore, alongside the services, we may use other anti-cheat technology.

6. International data transmission

The Company provides services all over the world and for the provision of the Company's services, we may transmit user data to countries and locations outside that of the user. When personal data of users are transmitted, saved, or processed by the Company, the Company shall take rational measures to protect the personal data of users. Currently, cases where the said data is processed in other countries for the purpose of provision of the Company's services are as follows:

  1. a. Customer service providers which process user inquiries and requests: the Republic of Korea, United States of America, Japan, and Taiwan
  2. b. Cloud storage service: Republic of Korea, Hong Kong Region

7. Holding and deleting personal information

As a rule, the Company deletes the personal information of users after the purpose of collecting personal information has been fulfilled. Physically stored personal information is shredded or burned and electronically stored personal information is deleted through recovery-proof technical measures. However, for the purpose of compliance with the Company's legal obligations, fulfill regulatory requirements, resolve disputes, prevent fraud, unlawful acts, or abuse, and when it is necessary to store the personal information of users to fulfill this policy or other contracts that the Company may sign with users, even after a user deletes their account or the Company ceases the provision of services, we may hold the personal information of users for a set amount of time.

8. The Company's policies concerning minors

Without consent from a verifiable parent or in cases permissible by law, the Company does not intentionally collect, use or share information from minors (the age limit is different for each country of residence). If you are a parent or legal guardian and think that the child may have given their data to the Company, you can contact the Company through the '13. Contact Details' section to request the deletion of the child's information from the Company's system.

9. Links and external services

Clicking on an external website link including but not limited to advertisements will result in leaving this website and opening the corresponding website. We are not able to control the activities of other companies, and shall not be held liable for the use of personal data of users by such third companies, and cannot provide assurance that they may comply with safe personal data protection and security protocols. It is wise to review the personal data Privacy Policies of the other service provider that you wish to engage with. When visiting another website linked to the game or the services, you must check the Privacy Policy and sections related to the protection of personal data of said website before providing personal data.

10. Protection of user information

The Company has taken adequate protective measures to protect the personal data of users including encryption and nonidentifier measures. Furthermore, we limit access to personal data of users to members of the staff and agents who require them for work purposes. These parties shall process the personal information according to the orders and in adequate circumstances, have the obligation of confidentiality. However, data transmittal through the Internet is not 100% safe and thus we cannot assure you of the complete security of the information that we collect and use.

11. Grounds for personal user data processing

The grounds for the Company processing the personal data of users are as follows:

  1. a. Fulfillment of the service provision contract of the Company
  2. b. Guaranteeing legal benefits for the business and the clients via improving services using the information on service usage and detecting and preventing malicious use for the protection of user information
  3. c. Approval from the user as a principal of personal data
  4. d. Compliance with other legal obligations

12. User rights to personal information protection

According to limitations of relevant laws, users have the right to object to or request limitations to personal user data processing and have the right to request access, modification, deletion, and transferal of personal user data. Should you have requests or other inquiries about user rights, please send an email to the address listed under the '13. Contact Details' section to contact the Company. According to the relevant data protection acts, the Company responds to the requests of users who wish to exercise their data protection rights.

13. Amendment

The Company may amend portions of this policy at the Company's discretion at any time by posting or marking the amended policy on the Company website. By continuing to use the services, users are deemed to have expressed consent to the amended policy. As such, we advise you to review it frequently.

14. Contact Details

Should you have any inquiries about this policy or the Company's personal data usage, please direct the inquiries via email to the data protection manager at

[Supplementary conditions – by jurisdiction]

Additional terms pertinent to the jurisdiction of users using the games and services - should there be discrepancies or conflicts between a particular jurisdiction and the remaining portions of the policy, the corresponding jurisdiction's additional terms - particular jurisdiction shall take precedence.

1. EEA, Switzerland, UK

If you are a resident of EEA, Switzerland, or the UK, you have additional rights.

  1. 1) International data transmission

    If the Company transmits the data to a country outside EEA not acknowledged by the European Commission as ensuring an adequate level of data protection, the Company must strive to undertake adequate measures to protect the personal data following the applicable data protection and personal information protection laws. These protective measures may include a data transmission contract that actualizes the latest standard contract terms (a type of data transmission contract approved beforehand by the European Commission as providing adequate protective measures for personal data). As stated in this policy, you may contact the Company and request a copy of said adequate measures. Aside from this, the Company transmits personal data to obtain convincing and lawful benefits in a method that does not involve seeking user approval, violation of fulfillment of contracts with you, or obstruction of the rights and freedom.

  2. 2) User rights to personal information protection

    Should users have doubts about the methods through which the Company processes the personal data, they have the right to raise complaints to corresponding data protection authorities. In particular, the data protection authorities to which you may direct the complaints may be in the area you work in or the area where the Company has been established in.

  3. 3) EU agent

    GDPR (for residents of the EU) for controllers or processors not based in the EU must have an agent in the EU, designated via a written form. The contact details and address of the Company's agency in the EU—VeraSafe—are as follows. Please direct the inquiries on personal data processing to VeraSafe.

    1. a. Company name: VeraSafe Netherlands BV
    2. b. Address: Keizersgracht 391 A 1016 EJ Amsterdam The Netherlands
    3. c. Inquiries:

    In the case of GDPR UK, the contact details and address of the Company's agency in the United Kingdom, VeraSafe, are as follows. Please direct the inquiries on personal data processing to VeraSafe.

    1. a. Company name: VeraSafe United Kingdom Ltd.
    2. b. Address: 37 Albert Embankment London SE1 7TL United Kingdom
    3. c. Inquiries:

2. California

The Company complies with the Consumer Privacy Act of the state of California.

  1. 1) Collected information

    The Company collects information that may distinguish and identify the service user or the user's device and relevant connecting information. During the last 12 months, the Company has collected the following personal information from users.

    1. a. Identifier - Username, exclusive identifier, online ID, IP, email address, account name, or a comparable ID
    2. b. Commercial information - Records on items of purchase/obtainment/collection or services, records of other purchases, purchase history or trends
    3. c. Geographical location data - Geolocational data such as country of residence
  2. 2) Purpose of data collection

    The information collected from users is used and shared for the following purposes

    1. a. Resolution of technical problems and improvement of the Company service quality
    2. b. Identification of users for the purpose of service provision
    3. c. Technical protection against non-authorized program usage in regard to the provided services
    4. d. Prevention of inappropriate game usage that may have a negative effect on the service and other users
    5. e. Customer support includes collecting and replying to customer inquiries
    6. f. Provision of the Company's services such as games and websites
    7. g. Provision of information on events, surveys, and opportunities of participation thereto, advertisement, and other marketing purposes
    8. h. Analysis of user trends and calculation of service usage statistics
  3. 3) Prohibition of sales

    The Company does not sell the information of the Company's users for financial profits or particular gains of the Company.

  4. 4) Prohibition of discrimination

    Some features of the Company's services may be archived or no longer provided, but the Company does not discriminate against users who exercise their CCPA rights.

  5. 5) User rights

    CCPA provides particular rights to individuals (residents of the state of California) on their personal information, and these rights may be exercised through the following methods.

    1. a. Access to certain information and data transferal rights

      You have the right to request disclosure of information on user data collection and usage during the past 12 months. The Company shall verify the user identity for the user request according to procedures and shall disclose the following information.

      - The scope of personal data the Company has collected from you

      - The scope of the personal data source the Company has collected from you

      - Business or commercial purposes for collecting personal data or for sales

      - The range of third parties with which the Company shares the subject's personal data with

      - Particular personal data the Company has collected from you

      - If the Company has shared the personal data for business purposes, an explanation on to what extent personal data is collected through what means and how they are used by the shared party

    2. b. Rights to request deletion

      According to special exemptions, you have the right to request the deletion of the personal information that the Company has collected from you and is holding. After receiving a request from an identifiable user and having the request confirmed, aside from exempted cases, your personal information shall be deleted.

      However, in exceptional cases involving security breaches, prosecution for illegal use, prior consent being provided beforehand, the impossibility of deletion, or compliance with relevant legal obligations, the information shall not be subject to deletion.

    3. c. Exercising rights

      You can exercise your rights as a user by drawing up the following form and submitting it through one of the following channels.

      - Email:

      - Form: California Consumer Privacy Act Request Form

      Only you or an authorized agent of you may exercise the rights and you may exercise the rights on behalf of a minor child.

      User requests may be submitted twice within a 12-month period and must meet the following conditions.

      - Sufficient information that allows the rational verification of the identity of the user themselves or their authorized agent

      - Sufficient and detailed explanation to allow for adequate understanding, evaluation, and response to requests for the exercising of rights

    4. d. Response format

      When a request from a verified user has been received, the Company strives to give a response within 45 days. If more time is needed (90 days maximum), we will notify you in writing about the reason and the length of the delay. All information disclosed by the Company shall only be from the 12 months immediately preceding the date of receipt of the user request.

      No commission shall be charged for processing or responding to the requests of a verified user aside from excessive or repetitive cases or cases without clear grounds. When commissions must be charged, information on the reason and the expected fee shall be provided.