1. INTRODUCTION
- 1.1 Welcome to the Garena website run by Garena Online Private Limited and its affiliates
and related corporations
(individually and collectively, "Garena", "we", "us" or "our"). Garena takes its
responsibilities under applicable
privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the
privacy rights and
concerns of all users of our Garena games (“Games”) and website (the "Site") (we refer to
the Games, Site and the
services we provide collectively as the "Services"). We recognize the importance of the
personal data you have
entrusted to us and believe that it is our responsibility to properly manage, protect and
process your personal
data. This policy (“Privacy Policy”) is designed to assist you in understanding how we
collect, use, disclose and/or
process the personal data you have provided to us and/or possess about you, whether now or
in the future, as well as
to assist you in making an informed decision before providing us with any of your personal
data. This Privacy Policy
is also designed to assist our users who live in the European Union (the “EU”) to understand
their applicable data
privacy rights that exist under the EU's General Data Protection Regulation when they use
the Services.
- 1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual
who can be identified
from that data, or from that data and other information to which an organisation has or is
likely to have access.
Common examples of personal data could include name, identification number and contact
information.
- 1.3 By using the Services, registering for an account with us or visiting our Site, you
acknowledge and agree that
you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and
you hereby consent to
us collecting, using, disclosing and/or processing your personal data as described herein.
- 1.4 IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS
PRIVACY POLICY, PLEASE DO
NOT USE OUR SERVICES OR ACCESS OUR GAMES OR SITE. If we change our Privacy Policy, we will
post those changes or the
amended Privacy Policy on the Site. We reserve the right to amend this Privacy Policy at any
time.
2. WHEN WILL GARENA COLLECT PERSONAL DATA?
- 2.1 We will/may collect personal data about you:
- • when you register and/or use our Services, Games or Site, or open an account with
us;
- • when you submit any form, including, but not limited to, application forms or
other
forms relating to any of
our products and services, whether online or by way of a physical form;
- • when you enter into any agreement or provide other documentation or information in
respect of your
interactions with us, or when you use our products and services;
- • when you interact with us, such as via telephone calls (which may be recorded),
letters, fax, face-to-face
meetings, social media platforms and emails;
- • when you use our electronic services, or interact with us via our Games or Site or
use
our Services. This
includes, without limitation, through cookies which we may deploy when you interact
with
our Games or Site;
- • when you carry out transactions through our Games or Site;
- • when you provide us with feedback or complaints;
- • when you register for a contest, for games or game specific events;
- • during your gameplay; and
- • when you submit your personal data to us for any reason.
The above does not purport to be exhaustive and sets out some common instances of when personal
data about you may be
collected.
3. WHAT PERSONAL DATA WILL GARENA COLLECT?
- 3.1 The personal data that Garena may collect includes but is not limited to:
- • name;
- • email address;
- • date of birth;
- • billing address;
- • bank account and payment information;
- • telephone number;
- • gender;
- •information sent by or associated with the device(s) used to access our Services;
- • any other information about the user when the user signs up to use our Services,
and
when the user uses the
Services, as well as information related to how the user uses our Services; and
- • aggregate data on content the user engages with.
- 3.2 You agree not to submit any information to us which is inaccurate or misleading, and you
agree to inform us of
any inacuracies or changes to such information. We reserve the right at our sole discretion
to require further
documentation to verify the information provided by you.
- 3.3 If you sign up to be a user of our Services using your social media account (“Social
Media Account”), link
your account to your Social Media Account or use any Garena social media features, we may
access information about
you which you have voluntarily provided to your Social Media Account provider in accordance
with such provider's
policies, and we will manage and use such personal data in accordance with this Policy at
all times.
- 3.4 If you do not want us to collect the aforementioned information/personal data, you may
opt out at any time by
notifying our Data Protection Officer in writing. Further information on opting out can be
found in the section
below entitled "How can you withdraw consent, remove, request access to or modify
information you have provided to
us?" . Note, however, that opting out or withdrawing your consent for us to collect, use or
process your personal
data may affect your use of the Services. For example, opting out of the collection of
location information will
cause its location-based features to be disabled.
4. COLLECTION OF OTHER DATA
- 4.1 As with most websites and mobile applications, your device sends information which may
include data about you
that gets logged by a web server when you use our Services. This typically includes without
limitation your device’s
Internet Protocol (IP) address, computer/mobile device operating system and browser type,
type of mobile device, the
characteristics of the mobile device, the unique device identifier (UDID) or mobile
equipment identifier (MEID) for
your mobile device, the address of a referring web site (if any), the pages you visit on our
website and mobile
applications and the times of visit, and sometimes a "cookie" (which can be disabled using
your browser preferences)
to help the site remember your last visit. If you are logged in, this information is
associated with your personal
account. The information is also included in anonymous statistics to allow us to understand
how visitors use our
Games and Site.
- 4.2 Our mobile applications may collect precise information about the location of your
mobile device using
technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this
information for one or more
purposes including, without limitation, location-based services that you request or to
deliver relevant content to
you based on your location or to allow you to share your location to other Users as part of
the services under our
mobile applications. For most mobile devices, you are able to withdraw your permission for
us to acquire this
information on your location through your device settings. If you have questions about how
to disable your mobile
device's location services, please contact your mobile device service provider or the device
manufacturer.
5. COOKIES
- 5.1 We may from time to time implement "cookies" or other features to allow us or third
parties to collect or
share information that will help us improve our Site, Games and the Services we offer, or
help us offer new services
and features. “Cookies” are identifiers we transfer to your computer or mobile device that
allow us to recognize
your computer or device and tell us how and when the Services or website are used or
visited, by how many people and
to track activity within our Site and Games. We may link cookie information to personal
data. Cookies also link to
information regarding what items you have selected for purchase pages you have viewed, or
games you have played.
This information is used to keep track of your shopping cart, for example. Cookies are also
used to deliver content
specific to your interest and to monitor usage of the Services.
- 5.2 You may refuse the use of cookies by selecting the appropriate settings on your browser.
However, please note
that if you do this you may not be able to use the full functionality of our Site, Games or
the Services.
6. HOW DO WE USE THE INFORMATION YOU PROVIDE US?
- 6.1 We may collect, use, disclose and/or process your personal data for one or more of the
following purposes:
- (a)to consider and/or process your application/transaction with us or your
transactions
or communications with
third parties via the Services;
- (b)to manage, operate, provide and/or administer your use of and/or access to our
Services, Site and Games
(including, without limitation, your preferences), as well as your relationship and
user
account with us;
- (c)to respond to, process, deal with or complete a transaction and/or to fulfil your
requests for certain
products and services and notify you of service issues and unusual account actions;
- (d)to enforce our Terms of Service or any applicable end user license agreements;
- (e)to protect personal safety and the rights, property or safety of others;
- (f)for identification and/or verification;
- (g)to maintain and administer any software updates and/or other updates and support
that
may be required from
time to time to ensure the smooth running of our Services;
- (h)to deal with or facilitate customer service, carry out your instructions, deal
with
or respond to any
enquiries given by (or purported to be given by) you or on your behalf;
- (i)to contact you or communicate with you via voice call, text message and/or fax
message, email and/or postal
mail or otherwise for the purposes of administering and/or managing your
relationship
with us or your use of our
Services, such as but not limited to communicating administrative information to you
relating to our Services. You
acknowledge and agree that such communication by us could be by way of the mailing
of
correspondence, documents or
notices to you, which could involve disclosure of certain personal data about you to
bring about delivery of the
same as well as on the external cover of envelopes/mail packages;
- (j)to inform you when another user has sent you a private message or posted a
comment
for you on the Games or
Site;
- (k)to conduct research, analysis and development activities (including, but not
limited
to, data analytics,
surveys, product and service development and/or profiling), to analyse how you use
our
Services, to improve our
Services or products and/or to enhance your customer experience;
- (l)to allow for advertising and other audits and surveys to, among other things,
validate the size and
composition of our target audience, and understand their experience with Garena’s
Services;
- (m)for marketing and, in this regard, to send you by various modes of communication
marketing and promotional
information and materials relating to products and/or services (including, without
limitation, products and/or
services of third parties whom Garena may collaborate or tie up with) that Garena
(and/or its affiliates or
related corporations) may be selling, marketing or promoting, whether such products
or
services exist now or are
created in the future. You can unsubscribe from receiving marketing information at
any
time by using the
unsubscribe function within the electronic marketing material. We may use your
contact
information to send
newsletters from us and from our related companies;
- (n)to respond to legal processes or to comply with or as required by any applicable
law,
governmental or
regulatory requirements of any relevant jurisdiction, including, without limitation,
meeting the requirements to
make disclosure under the requirements of any law binding on Garena or on its
related
corporations or affiliates;
- (o)to produce statistics and research for internal and statutory reporting and/or
record-keeping requirements;
- (p)to carry out due diligence or other screening activities (including, without
limitation, background checks)
in accordance with legal or regulatory obligations or our risk management procedures
that may be required by law
or that may have been put in place by us;
- (q)to audit our Services or Garena's business;
- (r)to prevent or investigate any fraud, unlawful activity, omission or misconduct,
whether relating to your use
of our Services or any other matter arising from your relationship with us, and
whether
or not there is any
suspicion of the aforementioned;
- (s)to store, host, back up (whether for disaster recovery or otherwise) of your
personal
data, whether within or
outside of your jurisdiction;
- (t)to deal with and/or facilitate a business asset transaction or a potential
business
asset transaction, where
such transaction involves Garena as a participant or involves only a related
corporation
or affiliate of Garena as
a participant or involves Garena and/or any one or more of Garena's related
corporations
or affiliates as
participant(s), and there may be other third party organisations who are
participants in
such transaction. A
“business asset transaction” refers to the purchase, sale, lease, merger,
amalgamation
or any other acquisition,
disposal or financing of an organisation or a portion of an organisation or of any
of
the business or assets of an
organisation; and/or
- (u)any other purposes which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”).
- 6.2 As the purposes for which we will/may collect, use, disclose or process your personal
data depend on the
circumstances at hand, such purpose may not appear above. However, we will notify you of
such other purpose at the
time of obtaining your consent, unless processing of the applicable data without your
consent is permitted by the
Privacy Laws.
7. HOW DOES GARENA PROTECT CUSTOMER INFORMATION?
- 7.1 We implement a variety of security measures to ensure the security of your personal data
on our systems. User
personal data is contained behind secured networks and is only accessible by a limited
number of employees who have
special access rights to such systems. We will retain personal data in accordance with the
Privacy Laws and/or other
applicable laws. That is, we will destroy or anonymize your personal data when we have
reasonably determined that
(i) the purpose for which that personal data was collected is no longer being served by the
retention of such
personal data; (ii) retention is no longer necessary for any legal or business purposes; and
(iii) no other
legitimate interest warrant further retention of such personal data. If you cease using our
Services, or your
permission to use the Site, Games and/or the Services is terminated, we may continue
storing, using and/or
disclosing your personal data in accordance with this Privacy Policy and our obligations
under the Privacy Laws.
Subject to applicable law, we may securely dispose of your personal data without prior
notice to you.
8. DOES GARENA DISCLOSE THE INFORMATION IT COLLECTS FROM ITS VISITORS TO OUTSIDE
PARTIES?
- 8.1 In conducting our business, we will/may need to disclose your personal data to our third
party service
providers, agents and/or our affiliates or related corporations, and/or other third parties,
whether sited in
Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third
party service providers,
agents and/or affiliates or related corporations and/or other third parties would be
processing your personal data
either on our behalf or otherwise, for one or more of the above-stated Purposes. Such third
parties include, without
limitation:
- •our subsidiaries, affiliates and related corporations;
- •contractors, agents, service providers and other third parties we use to support
our
business. These include
but are not limited to those which provide administrative or other services to us
such
as mailing houses,
telecommunication companies, information technology companies and data centres;
- •a buyer or other successor in the event of a merger, divestiture, restructuring,
reorganization, dissolution or
other sale or transfer of some or all of Garena’s assets, whether as a going concern
or
as part of bankruptcy,
liquidation or similar proceeding, in which personal data held by Garena about our
users
is among the assets
transferred; or to a counterparty in a business asset transaction that Garena or any
of
its affiliates or related
corporations is involved in; and
- •third parties to whom disclosure by us is for one or more of the Purposes and such
third parties would in turn
be collecting and processing your personal data for one or more of the Purposes.
- 8.2 This may require, among other things, disclosing your gaming history and/or disclosing
records showing which
games were viewed by which IP addresses. We will also share statistical and demographic
information about our users
and their use of the Services with suppliers of advertisements and programming. This would
not include anything that
could be used to identify you specifically or to discover individual information about you.
- 8.3 Additionally, you may elect to export your user activity feeds as RSS feeds which may be
subscribed to by
other users, which may include information regarding your game play, installation of games,
connections with other
users and other information about your account activity which is published as a feed on the
Site or Games.
- 8.4 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws
permit an organisation
such as us to collect, use or disclose your personal data without your consent, such
permission granted by the laws
shall continue to apply.
- 8.5 Third parties may unlawfully intercept or access personal data transmitted to or
contained on the site,
technologies may malfunction or not work as anticipated, or someone might access, abuse or
misuse information
through no fault of ours. We will nevertheless deploy reasonable security arrangements to
protect your personal data
as required by the Privacy Laws; however there can inevitably be no guarantee of absolute
security such as but not
limited to when unauthorised disclosure arises from malicious and sophisticated hacking by
malcontents through no
fault of ours.
9. INFORMATION ON CHILDREN
- 9.1 The Services are not intended for children under the age of 10. We do not
knowingly collect or maintain
any personal data or non-personally-identifiable information from anyone under the age
of 10 nor is any part of
our Site, Games or other Services directed to children under the age of 10. We will
close any accounts used
exclusively by such children and will remove and/or delete any personal data we believe
was submitted by any child
under the age of 10.
10. INFORMATION COLLECTED BY THIRD PARTIES
- 10.1 Our Site and Games use Google Analytics, a web analytics service provided by Google,
Inc. ("Google"). Google
Analytics uses cookies, which are text files placed on your device, to help the website
analyse how users use our
Services. The information generated by the cookie about your use of the Services or device
(including your IP
address) will be transmitted to and stored by Google on servers in the United States. Google
will use this
information for the purpose of evaluating your use of our Services, compiling reports on
website activity for
website operators and providing other services relating to website activity and Internet
usage. Google may also
transfer this information to third parties where required to do so by law, or where such
third parties process the
information on Google's behalf. Google will not associate your IP address with any other
data held by Google.
- 10.2 We, and third parties, may from time to time make software applications downloads
available for your use on
or through the Services. These applications may separately access, and allow a third party
to view, your
identifiable information, such as your name, your User ID, your device’s IP Address or other
information such as
what game you are playing during any given session, and any cookies that you may previously
have installed or that
were installed for you by a third party software application or website. Additionally, these
applications may ask
you to provide additional information directly to third parties. Third party products or
services provided through
these applications are not owned or controlled by Garena. You are encouraged to read the
terms and other policies
published by such third parties on their websites or otherwise.
11. DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES
- 11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU
PROVIDE ON THIRD PARTY
SITES. We do implement a variety of security measures to maintain the safety of your
personal data that is in our
possession or under our control. Your personal data is contained behind secured networks and
is only accessible by a
limited number of persons who have special access rights to such systems, and are required
to keep the personal data
confidential. When you place orders or access your personal data, we offer the use of a
secure server. All personal
data or sensitive information you supply is encrypted into our databases to be only accessed
as stated above.
- 11.2 In an attempt to provide you with increased value, we may choose various third party
websites to link to, and
frame within, the Site or Games. We may also participate in co-branding and other
relationships to offer e-commerce
and other services and features to our visitors. These linked sites have separate and
independent privacy policies
as well as security arrangements. Even if the third party is affiliated with us, we have no
control over these
linked sites, each of which has separate privacy and data collection practices independent
of us. Data collected by
our co-brand partners or third party web sites (even if offered on or through our Site or
Games) may not be received
by us.
- 11.3 We therefore have no responsibility or liability for the content, security arrangements
(or lack thereof) and
activities of these linked sites. These linked sites are only for your convenience and you
therefore access them at
your own risk. Nonetheless, we seek to protect the integrity of our Site and Games and the
links placed upon each of
them and therefore welcome any feedback about these linked sites (including, without
limitation, if a specific link
does not work).
12. WILL GARENA TRANSFER YOUR INFORMATION OVERSEAS?
- 12.1 Your personal data and/or information may be transferred to, stored or processed
outside of your country. In
most cases, your personal data will be processed in Singapore, where our servers are located
and our central
database is operated. Garena will only transfer your information overseas in accordance with
Privacy Laws. More
information about the transfer out of the EU, of personal data and/or information relating
to users who are located
in the EU, can be found in the section titled "Additional Provisions for EU Users Only".
13. HOW CAN YOU WITHDRAW CONSENT, REQUEST ACCESS TO OR CORRECT INFORMATION YOU HAVE PROVIDED
TO US?
Withdrawing Consent
- 13.1 You may withdraw your consent for the collection, use and/or disclosure of your
personal data in our
possession or under our control by sending an email to our Personal Data Protection Officer
at dpo.sg@garena.com.
- 13.2 However, your withdrawal of consent may mean that we will not be able to continue
providing the Services to
you, and we may need to terminate your existing relationship and/or the contract you have
with us.
Requesting Access to, or Correction of Personal Data
- 13.3 If you have an account with us, you may personally access and/or correct your personal
data currently in our
possession or control through the Account Settings page or tab on the Site or Games. If you
do not have an account
with us, you may request to access and/or correct your personal data currently in our
possession or control by
submitting a written request to us. We will need enough information from you in order to
ascertain your identity as
well as the nature of your request so as to be able to deal with your request. Hence, please
submit your written
request by sending an email to our Personal Data Protection Officer at dpo.sg@garena.com.
- 13.4 We may charge you a reasonable fee for the handling and processing of your requests to
access your personal
data. If we so choose to charge, we will provide you with a written estimate of the fee we
will be charging. Please
note that we are not required to respond to or deal with your access request unless you have
agreed to pay the fee.
- 13.5 We reserve the right to refuse to correct your personal data in accordance with the
provisions as set out in
Privacy Laws, where they require and/or entitle an organisation to refuse to correct
personal data in stated
circumstances.
14. ADDITIONAL PROVISIONS FOR EU USERS ONLY
- 14.1 The provisions in this Section only apply if you are a user who is located in the
European Union (“EU”).
These provisions take precedence over any inconsistent provisions in the remainder of this
Privacy Policy.
- 14.2 Portability
You have the right to obtain from us the Personal Data that you have previously provided to us,
and which we process
on the basis of your consent in a structured, commonly used and machine-readable format and a
right to request that we
transfer such Personal Data to another party. If you wish for us to transfer the Personal Data
to another party,
please ensure you detail that party and note that we can only do so where it is technically
feasible. We are not
responsible for the security of the Personal Data or its processing once received by the third
party. We also may not
provide you with certain Personal Data if providing it would interfere with another’s rights
(e.g. where providing the
Personal Data we hold about you would reveal information about another person).
- 14.3 Erasure
You may request that we erase the Personal Data we hold about you in the following
circumstances:
- (a)you believe that it is no longer necessary for us to hold the Personal Data we
hold
about you;
- (b)we are processing the Personal Data we hold about you on the basis of your
consent,
and you wish to withdraw
your consent and there is no other ground under which we can process the Personal
Data;
- (c)we are processing the Personal Data we hold about you on the basis of our
legitimate
interest and you object
to such processing. Please provide us with detail as to your reasoning so that we
can
assess whether there is an
overriding interest for us to process and retain such Personal Data;
- (d)you no longer wish us to use the Personal Data we hold about you in order to send
you
promotions, special
offers, marketing and lucky draws; or
- (e)you believe the Personal Data we hold about you is being unlawfully processed by
us.
Please provide as much detail as possible on your reasons for the request to assist us in
determining whether you have
a valid basis for erasure. However, we may retain the Personal Data if there are valid grounds
under law for us to do
so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if
that is the case.
Please note that after deleting the Personal Data, we may not be able to provide the same level
of servicing to you as
we will not be aware of your preferences.
- 14.4 Retention of Personal Data
We retain your Personal Data as long as needed to provide services or products to you, or as
required or permitted by
applicable laws, such as tax and accounting laws. If you make a request for erasure of your
Personal Data 3 and we
determine that there is a valid basis for your request, we will endeavour to erase the Personal
Data within 30 days of
your request, or inform you if it will take longer.
- 14.5 Objection against Profiling and Targeted Marketing
At any time you have the right to object to our processing of Personal Data about you in order
to send you promotions,
special offers and marketing messages, including where we build profiles for such purposes and
we will stop processing
the Personal Data for that purpose. Please provide as much detail as possible on your reasons
for the request to
assist us in determining whether you have a valid basis for objection. However, we may retain
the Personal Data if
there are valid grounds under law for us to do so.
- 14.6 Restriction of Processing to Storage Only
You have a right to request that we restrict the processing of the Personal Data we hold
about
you to storage purposes
only, where:
- (a)you believe the Personal Data is not accurate, for the period it takes for us to
verify whether the Personal
Data is accurate;
- (b)we wish to erase the Personal Data but you want us to just store it instead;
- (c)we wish to erase the Personal Data as it is no longer necessary for our purposes
but
you require it to be
stored for the establishment, exercise or defence of legal claims; or
- (d)you have objected to us processing Personal Data we hold about you on the basis
of
our legitimate interest
and you wish us to stop processing the Personal Data whilst we determine whether
there
is an overriding interest
in us processing and retaining such Personal Data.
- 14.7 Transfer of Personal Data outside the EU
Your Personal Data may be transferred outside of the EU. We take appropriate steps to ensure
that recipients of your
Personal Data are bound to duties of confidentiality and we implement measures such as
appropriate contractual clauses
to ensure that the recipients of such transfer protect and treat your Personal Data in
accordance with all applicable
personal data protection laws.
- 14.8 Information on Children
The Services are not intended for children under the age of 16 who are located in the EU. We do
not knowingly collect
or maintain any personal data or non-personally-identifiable information from anyone under the
age of 16 who is
located in the EU, nor is any part of our Site, Games or other Services directed to children
under the age of 16 who
are located in the EU. We will close any accounts used exclusively by such children and will
remove and/or delete any
personal data we believe was submitted by any child under the age of 16 who is located in the
EU.
15. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
- 15.1 If you have any questions, concerns or complaints about our privacy practices, please
contact us at
dpo.sg@garena.com.
Last modified: 31 October 2019