Privacy Policy

Table of Contents

  1. General Provisions
  2. Purposes and Categories of Personal Information Collected and Used
  3. Methods of Collecting Personal Information and Obtaining Consent
  4. Entrustment of Personal Information Processing
  5. Provision of Personal Information to Third Parties
  6. Retention and Use Period of Personal Information
  7. Procedures and Methods for Destruction of Personal Information
  8. Rights and Obligations of Customers and Methods of Exercise
  9. Protection of Children’s Personal Information and Rights of Legal Representatives
  10. Installation, Operation, and Refusal of Automated Personal Information Collection Devices
  11. Technical and Administrative Measures for Protection of Personal Information
  12. Transmission of Commercial Advertising Information
  13. Cross-Border Transfer of Customer Personal Information
  14. Processing of Pseudonymous Information
  15. Feedback and Grievance Resolution
  16. Data Protection Officer and Responsible Department
  17. Amendments to the Privacy Policy

 

1. General Provisions

KONG STUDIOS Inc. (hereinafter referred to as the "Company") establishes and discloses this Privacy Policy in accordance with Article 30 of the Personal Information Protection Act to protect customers' personal information and promptly resolve related grievances.

Under this Privacy Policy, “Personal Information” refers to information relating to a living individual that falls under any of the following categories:

  1. Information that identifies a specific individual by name, resident registration number, connecting information (CI), images, or other identifying characteristics;
  2. Information that, even if it cannot identify a specific individual on its own, can easily be combined with other information to identify the individual;
  3. Information processed by deleting or replacing a portion of the information under items (1) or (2) above (pseudonymization) so that a specific individual cannot be identified without the use or combination of additional information (hereinafter referred to as “Pseudonymous Information”).

The Company may amend this Privacy Policy pursuant to changes in applicable laws, regulations, governmental guidelines, or internal operational policies. Amendments, including the effective dates, may be reviewed at any time via the Privacy Policy notices section.

2. Purposes and Categories of Personal Information Collected and Used

The Company collects and uses personal information by distinguishing between “Mandatory Information” necessary for providing the Services and “Optional Information” used to deliver services customized to customer preferences and needs. Customers may still use the Services even if they withhold consent to the collection and use of Optional Information.

The Company may collect customer personal information and use it within the scope of the collection purposes under any of the following circumstances:

●      a. Where consent has been obtained from the customer;

●      b. Where special provisions exist in laws or where it is inevitable to comply with statutory obligations;

●      c. Where necessary for executing or performing a contract concluded with the customer, or implementing measures requested by the customer in the course of entering into a contract;

●      d. Where manifestly deemed necessary for the urgent benefit of the life, physical safety, or property of the customer or a third party;

●      e. Where necessary to attain the legitimate interests of the Company, which manifestly override the rights of the customer (limited to instances related to the Company’s legitimate interests and not exceeding a reasonable scope);

●      f. Where urgently required for public safety and well-being, such as public health.

Furthermore, pursuant to applicable laws and regulations, personal information may be used without the customer’s consent within a scope reasonably related to the initial purpose of collection.

In such circumstances, comprehensive consideration shall be given to: whether it is related to the initial purpose of collection; whether it is predictable in light of the circumstances of collection or customary processing practices; whether it infringes upon the interests of the customer unjustifiably; and whether necessary measures to ensure safety, such as pseudonymization or encryption, have been implemented.

The Company collects and uses personal information for the following purposes:

  1. User identification, verification of intent to subscribe, limitation of subscription attempts, prevention of fraudulent use by bad-faith members, verification of legal representative consent, and identity verification of legal representatives;
  2. Processing user inquiries and grievances during service use, and delivering operational notices;
  3. Service provision and settlement of fees for the purchase and use of paid services;
  4. Development of new services, notification of participation opportunities for events, marketing, and advertising;
  5. Analysis of service usage records and access frequency, provision of customized services, and service enhancement through service usage statistics;
  6. Establishment of a secure operating environment for user privacy protection;
  7. Optimization and stabilization of services based on AI technologies:

○      Detection of and response to abnormal gameplay (illegal software/unauthorized programs, etc.);

○      Analysis of customer support (CS) inquiries and improvement of customized response efficiency.

Personal Information Processed Without Consent (Mandatory Items)

Service Name

Category

Legal Basis

Collected Items

KONG STUDIOS Inc.

Guest Login

Article 15(1)(4) of the PIPA (Conclusion and Performance of a Contract)

Nickname, Device ID

 

※ Generated Information: Game Account No.

KONG STUDIOS Inc. - Customer Support

1:1 Inquiry

Article 15(1)(4) of the PIPA (Conclusion and Performance of a Contract)

Email address, Game Account No. (Not collected for non-member logins)

KONG STUDIOS Inc. - Customer Support

App Market Developer Email Inquiry

Article 15(1)(4) of the PIPA (Conclusion and Performance of a Contract)

Nickname, Email address, Server Info, Attached Files

KONG STUDIOS Inc.

Automatically Collected Information

Article 15(1)(4) of the PIPA (Conclusion and Performance of a Contract)

Game and service usage records, App ID, Device info (Model, OS version, Unique Device Identifier), Registration date, Login/Logout timestamps, Telecom carrier info, Country code, Payment records, Purchase time, Purchased items, Promotion/Event participation records, IP address, Store info, Adult verification status (for adult-only content)

 

Personal Information Processed With Consent (Optional Items / Specific Inquiries)

Service Name

Legal Basis

Collected Items

KONG STUDIOS Inc. - Customer Support

Article 15(1)(1) of the PIPA (Consent)

Character Name, Order Number (Google), Receipt Screenshot (Apple)

 

3. Methods of Collecting Personal Information and Obtaining Consent

Mandatory personal information necessary for service provision is collected during the account registration process or by providing advance notice and obtaining user consent. Where optional personal information is collected, the Company, in principle, notifies the user and obtains consent through the following methods:

  1. Information collected during account registration and service use, or entered directly by the user upon consenting to collection;
  2. Information provided by affiliated services, business partners, or external entities;
  3. Information collected via web pages, email, fax, or telephone during customer service consultations;
  4. Information collected through user participation in online or offline events and promotions.

4. Entrustment of Personal Information Processing

The Company executes data entrustment agreements governing: the prohibition of processing personal information outside the purpose of the entrusted tasks; technical and administrative safeguards; the purpose and scope of entrustment; restrictions on re-entrustment; access controls and other measures to ensure security; supervision and inspection of personal information management; allocation of liabilities in the event of personal information breaches; and the obligation to return or destroy personal information upon termination of processing.

For smooth business operations and to provide enhanced services and customer convenience, the Company entrusts the processing of personal information to specialized external contractors as set forth below. The list of entrusted entities (trustees) may be subject to change depending on service updates and contract periods. In such cases, notice will be provided via the methods designated for each service or through general announcements.

Status of Personal Information Processing Entrustment

Service Name

Sub-processor (Entrusted Entity)

Purpose of Entrustment

Retention and Use Period

KONG STUDIOS Inc.

ELITE GAMES Inc.

Customer Support operation and consultation

Until membership withdrawal or termination of the entrustment contract

KONG STUDIOS Inc.

Zendesk Korea

Infrastructure operation/management for Customer Support

Until membership withdrawal or termination of the entrustment contract

 

5. Provision of Personal Information to Third Parties

The Company uses personal information solely within the scope consented to by the customer or permitted by law, and does not use or disclose it to third parties beyond such scope.

However, pursuant to applicable laws, personal information may be provided to third parties without customer consent within a scope reasonably related to the initial purpose of collection. In such circumstances, the Company comprehensively evaluates: whether it is related to the initial purpose of collection; whether it is predictable in light of the circumstances of collection or customary processing practices; whether it unjustifiably infringes upon the interests of the customer; and whether necessary measures to ensure safety, such as pseudonymization or encryption, have been implemented.

Specifically, personal information may be provided within the aforementioned scope under the following circumstances:

●      a. Business Partnerships: The Company may provide or share personal information with affiliates to deliver enhanced services. Prior to doing so, the Company will notify the customer in writing or via email regarding the identity of the affiliate, the categories of data provided, the purpose, and the retention period, and obtain individual consent. If consent is refused, the information will not be provided or shared.

●      b. Mergers, Acquisitions, and Business Transfers: In the event of a full or partial business transfer, merger, or succession of rights and obligations, the Company will notify customers to guarantee their statutory rights regarding personal data protection.

●      c. Statutory Obligations: Where required under special provisions of other laws, such as the Framework Act on National Taxes or the Criminal Procedure Act. (Note: Personal information will not be disclosed unconditionally upon the administrative or investigative request of authorities; it will be provided strictly in accordance with lawful statutory procedures, such as upon presentation of a valid judicial warrant or official document bearing the seal of an agency head.)

●      d. Emergency Situations: In the event of disasters, infectious diseases, incidents posing imminent danger to life or physical safety, or imminent property loss. (Note: Data provision is strictly confined to the minimum necessary extent based on relevant statutory authority.)

Status of Third-Party Provision of Personal Information

Legal Basis

Third-Party Recipient

Purpose of Provision

Provided Items

Recipient's Retention and Use Period

Exercise of Rights

Additional Use / Provision

Article 17(4) of the PIPA

Apple Inc.

App Store payment transaction verification, refund request processing support, purchase/refund dispute resolution, verification of item provision and usage, prevention of fraudulent refunds

Status of successful provision and usage of game content products

Until the purposes of refund processing, dispute resolution, and fraudulent transaction prevention are achieved, or until the retention period required by Apple's laws and policies expires

In-game Customer Support

Evaluated in accordance with Article 17(4) of the PIPA

 

6. Retention and Use Period of Personal Information

The Company processes personal information within the retention and use period consented to by the user upon registration and service use. When a user withdraws consent, or upon achievement of the purpose of collection and use or expiration of the retention period, the personal information is destroyed without delay.

When account deletion is requested, game data is retained for 7 days to prepare for unintended withdrawals. The scope of retention follows each game's operational policy. In addition, fraudulent use records are retained for 5 years pursuant to internal policy.

7. Procedures and Methods for Destruction of Personal Information

The Company destroys personal information without delay when it becomes unnecessary, such as upon the expiration of the retention period or fulfillment of the processing purpose.

●      Electronic Files: Permanently deleted using technical methods that render the records irrecoverable. Where technical limitations preclude permanent deletion, the data is processed into anonymous information to prevent restoration.

●      Paper Documents: Shredded using a paper shredder or incinerated.

Statutory Retention of Personal Information

Where retention is mandated by applicable statutory provisions, the Company stores personal information in an isolated, separate database (DB) for the duration prescribed by such laws:

  1. Act on the Consumer Protection in Electronic Commerce, etc. (Article 6(1))

●      Records on display and advertising (Subparagraph 1): 6 months

●      Records on contracts or withdrawal of subscription, etc. (Subparagraph 2): 5 years

○      Retained Items: Purchaser information (Customer No./Game Account No.), product purchase, cancellation, exchange, and refund records

●      Records on payment and supply of goods, etc. (Subparagraph 3): 5 years

○      Retained Items: Payment details (transaction ID, purchase type, payment amount, payment gateway/carrier, payment timestamp), delivery/tracking number

●      Records on consumer complaints or dispute settlements (Subparagraph 4): 3 years

○      Retained Items: Customer No./Game Account No., contact information, email address, consultation logs (inquiry contents, consultation timestamps, voice recordings), inquiry contents and processing outcomes

  1. Framework Act on National Taxes (Article 85-3) and Corporate Tax Act (Article 112)

●      Account books and supporting documents for transactions governed by tax laws: 5 years

○      Retained Items: Name, resident registration number (limited strictly to processing for public taxes and levies), transaction dates, transaction amounts, payment history

8. Rights and Obligations of Customers and Methods of Exercise

A. Customer Rights Regarding Personal Information Protection

Customers may access or obtain copies of their personal information held by the Company, records regarding the use or third-party provision of their personal information, and records of consent granted for collection, use, and provision.

Upon a customer's request for access, provision, rectification, erasure, or data portability, the Company will respond faithfully without undue delay. Where personal information is determined to contain errors or the retention period has lapsed, the Company will rectify or erase the data immediately.

Customers may withdraw consent (terminate membership) regarding the collection, use, or provision of personal information at any time, and the Company will take necessary actions immediately. However, withdrawal of consent for information mandatory for membership registration and essential service delivery will result in account termination and service cancellation, precluding access to the Services.

B. Methods of Exercising Customer Rights

Customers may exercise their rights through the methods below:

●      Reception & Processing Department: KONG STUDIOS Inc. Infrastructure Dept.

●      Contact: 02-532-2063, Contact Us (support@gdtskr.zendesk.com)

When a customer requests access to their personal information, the Company shall take prompt measures to enable inspection and verification.

C. Obligations of Customers

Customers must ensure their personal information is entered accurately and kept up to date to prevent unforeseen incidents. Customers bear sole responsibility for incidents arising from inaccurate information provided. Any misappropriation of third-party information or submission of false data may result in membership forfeiture and penalties under the Terms of Service.

Customers must exercise reasonable care, including logging out from public devices, to prevent credentials (ID, password, etc.) and personal information from leaking. Customers should avoid easily inferable passwords and update passwords periodically. Customers must respect the personal data and rights of third parties and refrain from infringing or defaming them in public posts.

D. Rights Concerning Automated Decision-Making

The Company utilizes AI technology to enhance service efficiency and maintain operational fairness. Where an automated decision made by an AI system produces legal effects or significantly affects rights or obligations, customers have the right to request an explanation, request human review, or reject the automated decision. Please note that final decisions by the Company undergo human review by operational staff and do not constitute purely automated decisions.

9. Protection of Children’s Personal Information and Legal Representatives' Rights

As a rule, the Company does not collect personal information of children under the age of 14 (hereinafter referred to as "Children").

If a legal representative requests withdrawal from the Company's service on behalf of a child, instructions for account deletion will be provided. If processing a child's information is unavoidably required upon user request, consent from the legal representative will be obtained, and the relevant information will be destroyed without delay upon completion of the task.

10. Installation, Operation, and Refusal of Automated Personal Information Collection Devices

The Company may deploy and operate cookies and mobile advertising identifiers (Advertising ID / ADID) that store and retrieve customer information to remember preferences and provide efficient services.

Information collected via cookies and advertising identifiers may be used for the following purposes:

●      Delivering differentiated information based on areas of individual interest;

●      Analyzing navigation trails to provide personalized services on subsequent visits;

●      Displaying subscription periods when using paid services;

●      Analyzing user habits as metrics for service reorganization and improvement.

Cookie Refusal Guide

  1. What is a Cookie? A cookie is a very small text file sent to the user’s browser by the server operating the website and stored on the user’s computer hard drive.
  2. Why do we use cookies? The Company uses cookies to store user preferences, provide faster web environments, improve services, analyze visit patterns, and deliver customized services including advertisements.
  3. How to Refuse Cookie Collection: Users have the option to configure cookie settings. Through browser preferences, users may accept all cookies, require confirmation whenever a cookie is stored, or refuse the storage of all cookies. Refusing cookies may result in degraded web usability and difficulties accessing services that require login.

Browser Configuration:

●      Chrome: Settings > Privacy and Security > Cookies and other site data > Select preference.

●      Edge: Settings > Cookies and site permissions > Manage and delete cookies and site data > Select preference.

●      Safari: Preferences > Privacy > Select cookie blocking preferences.

●      Internet Explorer: Tools > Internet Options > Privacy > Settings.

Advertising Identifier (ADID/IDFA) Guide

  1. Customized Advertising: Interest-based advertising provides useful advertisements to users using behavioral information, such as service visit records, activity logs, and search histories. The Company utilizes Advertising IDs (unique identifiers issued by mobile operating systems) to deliver appropriate, personalized advertising.
  2. Protection of User Information: The Company does not collect sensitive information that may infringe on user rights, interests, or privacy, nor does it combine behavioral information collected via Advertising IDs with personally identifiable information without prior consent. Behavioral information is stored for a maximum of 1 year to provide customized advertisements and content based on demographic inferences and interests, after which it is destroyed using irrecoverable technical methods. The Company does not collect behavioral information from known children under 14, nor does it deliver customized advertising to children under 14.
  3. Opt-Out Instructions: Users may opt out of customized advertising at any time:

○      Android: Settings > Google > Ads > Opt out of Ads Personalization (or Delete advertising ID).

○      iOS: Settings > Privacy & Security > Tracking > Toggle off "Allow Apps to Request to Track".

11. Technical and Administrative Measures for Protection of Personal Information

Pursuant to Article 29 of the PIPA, the Company implements the following technical, administrative, and physical safeguards to prevent loss, theft, leakage, alteration, or damage of personal information:

●      a. Formulation and Execution of Internal Management Plans: The Company establishes, implements, and annually reviews an Internal Management Plan setting forth necessary standards for secure data processing.

●      b. Encryption of Personal Information: User personal information is transmitted over encrypted communication networks (SSL/TLS), and critical data, such as passwords, is encrypted at rest.

●      c. Protection Against Hacking and Malware: Systems are deployed within access-controlled physical areas to prevent breaches caused by hacking or viruses. Intrusion detection and prevention systems operate 24/7, and endpoint antivirus software is updated continuously to block malicious code.

●      d. Minimization and Training of Authorized Personnel: Access to personal information is restricted to the minimum necessary personnel. Work PCs are segregated from external internet services to prevent data leaks. Access rights to database systems are governed by strict credential policies and subjected to ongoing audits.

●      e. Regular Employee Training: Regular privacy and data security education and compliance campaigns are conducted for all personnel handling personal information.

●      f. Privacy-Centric AI Operations: Pseudonymization techniques are applied during AI model training and analysis to minimize personal data exposure. Data is destroyed without delay once training/analysis objectives are attained, and isolated processing environments are maintained to prevent unauthorized data exfiltration.

12. Transmission of Commercial Advertising Information

The Company does not transmit commercial advertising information for for-profit purposes without the customer's prior consent.

Where advertising information is transmitted for marketing purposes (such as new title releases or event notifications), the Company obtains prior express consent and implements identification labels across transmission channels as follows:

●      Email: The word (광고) or (Ad) is placed at the beginning of the subject line without spacing, followed by the main message body. Where technical constraints preclude displaying advertising labels in subject headers, necessary identification measures, including the sender's name, are displayed.

●      Mobile Messengers / SMS: The sender's corporate identity and opt-out mechanisms are clearly displayed.

The Company notifies the customer via pop-up or electronic confirmation upon consent acquisition, opt-out, or withdrawal of consent. Furthermore, pursuant to applicable regulations, the Company re-confirms the customer's consent status every two (2) years from the date consent was granted.

13. Cross-Border Transfer of Customer Personal Information

Where necessary, the Company entrusts the processing or storage of customer personal information overseas as follows. Refusal of overseas transfer can be exercised through game withdrawal (In-game Settings → Delete Account or Customer Support). Please note that game services cannot be utilized upon withdrawal.

Status of Cross-Border Personal Information Transfer

Legal Basis

Transferred Items

Destination Country, Timing, and Method of Transfer

Recipient

Recipient's Purpose of Use and Retention Period

Method, Procedure, and Effect of Refusing Cross-Border Transfer

Entrustment and Storage of Cross-Border Processing for Contract Performance

 

(Article 28-8(1)(3) of the PIPA)

Game Nickname, Game Account No., Service usage records

Japan, USA, Singapore, Germany

 

 

Transmitted via encrypted API communication at the time of service use

Amazon Web Services Inc.

 

(Contact: https://aws.amazon.com/compliance/contact)

Entrustment of game infrastructure management tasks

 

 

Until game account withdrawal or termination of the game service

Refusal of cross-border transfer can be exercised by withdrawing from the game service via the in-game withdrawal function or the membership withdrawal page. Service use is prohibited after withdrawal.

Entrustment and Storage of Cross-Border Processing for Contract Performance

 

(Article 28-8(1)(3) of the PIPA)

Status of successful provision of game content products

USA

 

 

Transmitted via encrypted API communication when the market operator requests verification of successful item provision and usage

Amazon Web Services Inc.

 

(Contact: https://aws.amazon.com/compliance/contact)

Storage for processing the market operator's requests to verify the provision of game content products

 

 

User inquiries and disputes (3 years)

Requests to halt cross-border transfers can be made to Customer Support. The Company will verify identity and notify the outcome of the refund/dispute review. However, halting the transfer may pause the market operator's refund review or delay refund processing. If Terms of Service violations such as fraudulent refunds are identified, usage restrictions may be applied in accordance with the Terms.

 

14. Processing of Pseudonymous Information

The Company may process personal information in the form of pseudonymous information (which cannot identify a specific individual without additional data) for statistical purposes and scientific research. Pseudonymous information is stored and managed separately from additional data, with necessary technical, administrative, and physical safeguards applied to prevent re-identification.

  1. Purpose of Processing: Service improvements through statistics and analysis, and establishment of a secure service environment.
  2. Processing and Retention Period: Retained until completion of the relevant research, analytics, or statistical project.
  3. Provision to Third Parties: None.
  4. Entrustment of Processing: None.
  5. Categories of Pseudonymized Data: Service usage records.
  6. Safeguards for Pseudonymous Information:

○      Administrative Measures: Establishment and execution of internal management plans; periodic employee training.

○      Technical Measures: Access authority management for processing systems; intrusion prevention systems; separate storage and management of source datasets; installation of security programs.

○      Physical Measures: Access controls for data storage facilities.

15. Feedback and Grievance Resolution

The Company values customer feedback. Contact info:

●      Phone: 02-532-2063

●      Inquiry: support@gdtskr.zendesk.com

For consultations or dispute mediation regarding personal data infringement, users may contact the following statutory agencies:

Agency

Telephone

Website

Personal Information Dispute Mediation Committee

(Without area code) 1833-6972

www.kopico.go.kr

Personal Information Infringement Report Center (KISA)

(Without area code) 118

privacy.kisa.or.kr

Supreme Prosecutors' Office (Cybercrime Investigation Division)

(Without area code) 1301

www.spo.go.kr

National Police Agency (Cyber Bureau)

(Without area code) 182

ecrm.police.go.kr

 

16. Data Protection Officer and Department

The Company Privacy Officer and responsible department provisions have been updated as follows:

●      Data Protection Officer: Jinsoo Baik (Executive Director)

●      Department: Infrastructure Dept.

●      Contact: 02-532-2063, Contact Us (support@gdtskr.zendesk.com)

17. Modifications to Privacy Policy

This Privacy Policy shall take effect on October 27, 2026.