KRAFTON

Privacy Policy

Effective and Last Revised Date: 2023.11.21

1. Introduction

KRAFTON (LIST of our affiliates) (“KRAFTON”, “we”, “our”, “company” or “us”) collect and process information about you (“you”, “user”, or “applicants”) when you visit, access, or use our websites (including our careers page or press site) (“Sites”). KRAFTON refers to KRAFTON, Inc. and its subsidiary and affiliated entities which provide or develop games and services under in different locations. This Privacy Policy(“Policy”) describes how we collect and use personal information about you during and after your relationship with us. By visiting our Sites or applying to our company you acknowledge the practices described in this Policy.

We will occasionally update this Policy. When we do, we will revise the effective date above. Your continued use of our website after such changes means you accept the Policy as revised. We encourage you to periodically review this Policy to stay informed about how we collect and process your personal information.

2. Information We Collect

What personal information we collect and process depends on how and why you interact with us.

• A)Information you provide us: We collect information that you provide directly to us when you use our Sites. Where we can, we aim to obtain consent before collecting or processing special categories of sensitive personal data (including veteran or disability information). For example, you may provide us with your:

  Purpose	Personal Information
  To provide and manage our Sites, including inquiries and requests received from you through the Sites (e.g. through a Speak Up session, to respond to a partnership inquiry, media inquiries, etc.)	Name, email address, and any information you send us via our website, etc.
  To answer your inquiries related to branding or other opportunities	Name, email address, name of the affiliated department, or phone number, etc.
  To assess potential job applicants and progress through the recruitment process	Name, email address, phone number, date of birth, pictures, nationality(e.g. where you live), postal address, professional information, or other information that you wrote in your resume

• B)Information we collect automatically: We automatically collect certain information when you visit our Sites, some of which could be considered personal information (also known as “Session Data”). Session Data we automatically collect may vary, but generally includes:

  • –Your device information (including OS version, model information, device ID, etc.);
  • –Online identifiers (including IP address, MAC address, etc.);
  • –What areas of the websites you accessed, browsed, searched for, or used; and
  • –Time spent on our websites and related statistical information.

  We do not use Session Data to personally identify you. We use it to administer, operate, and improve our Sites. The process by which we collect this information is through cookies related online technologies. See our “Cookies and Related Technologies” section below for more information.

• C)

  Information we collect from third-parties:

  When you apply to our company using third-party platforms, we may receive certain information from your profile/account on third-party platforms as permitted by the terms of the third-party platform and your privacy settings thereon. For example, if you apply with LinkedIn profile, we receive your resume that is saved in LinkedIn.

3. How We Use Your Information

We use personal information collected through the Sites for the following purposes:

• –Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity;
• –Comply with and enforce legal requirements, agreements, and policies; and
• –Achieve purposes for which we provide specific notice at the time of collection.

In the majority of cases, our processing of your personal information is necessary to respond to you or process your request. We may also process your information to comply with a relevant legal obligation. For example, we may process your personal information to comply with legal obligations related to screening job applicants for employment, which may require the maintenance of certain records and for us to make mandatory disclosures to authorities. From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal by contacting us at the address provided in this Policy.

4. Sharing Your Information

We may share personal information with the following categories of parties and as otherwise described in this Policy or at the time of collection:

• –With our affiliates for the purposes described in this Policy, including to assess job applicants, progress the recruitment process, and respond to inquiries;
• –With our service providers who help us perform and deliver our services, including: cloud service provider, website management, hosting, and analytics; communications; form processing; information technology and security; job application systems providers; recruitment providers; and auditing;
• –With the appropriate authorities if we believe disclosure is necessary to prevent physical, financial, or other harm, injury, or loss, including to protect against fraud or credit risk;
• –With legal, governmental, or judicial authorities as instructed or required by those authorities and applicable laws, or in relation to a legal activity, such as in response to a subpoena or investigation of suspected illicit or illegal activities, or where we believe in good faith that users may be engaged in illicit or illegal activities, or where we are bound by contract or law to enable a network partner to comply with applicable laws; and
• –With necessary third parties in connection with, or during negotiations for, an acquisition, merger, asset sale, or other similar business transfer that involves all or substantially all of our assets or functions where personal information is transferred or shared as part of the business assets.

5. Cookies and Related Technologies

As noted above, we use cookies and other technologies (like pixels, tags, and web beacons) when you interact with our Sites to improve their quality, store browsing preferences, and track usage trends, among other things. For these technologies to work, third parties collect and/or receive information from our Sites and elsewhere on the internet. These third parties typically collect information in the aggregate and in a way that does not personally identify you

Among other things, we use cookies from Google including Google Analytics. You can learn more about how those cookies work by visiting “How Google uses information from sites or apps that use our services,” located at https://policies.google.com/technologies/partner-sites. We do not control cookies in third party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. Please note, however, if you do not accept necessary cookies, some website features or services may not function properly. To find out more about cookies, visit http://www.allaboutcookies.org/.Note, we do not process or respond to web browsers’ “do not track” signals. To find out more about “do not track,” please visit http://www.allaboutdnt.com

6. International Data Transfers

We recruit and make access to our Sites available to users, globally. Consequently, to provide our Sites and services and/or to meet legal requirements we may transfer your data to other countries and other regions outside of where you are located. By using our Sites and/or applying for a position, if applicable, you acknowledge that your personal information may be processed in a location outside of your own. For certain countries, we process the data in certain regions (as set out in more details below).

7. Retaining and Deleting Personal Information

We generally retain your personal information for the duration of your relationship with us and will delete it after the purpose of the collection is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using commercially reasonable technical measures in a way that the data cannot be reproduced.

8. Our Policy Concerning Children

We do not knowingly collect, use or share any personal information about children (age depending on the country where you reside) through our Sites. If you are a parent or guardian and you believe your child has provided us with personal information, you can contact us and request your child’s information to be deleted from our system.

9. Links and Third-Party Services

If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave the Site and go to the website you selected. Because we cannot control the activities of third parties, we do not hold any responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to our Sites, you should consult that site’s privacy policy before providing any personal information.

10. Protecting Your Information

While no one can guarantee your personal information is completely secure at all times, we use administrative, organizational, technical, and physical safeguards to help protect the personal information we collect and process. Our security controls are designed to maintain data confidentiality, integrity, and give us appropriate access to your data. Among other things, we update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. We use professional third-party service providers, data centers to provide our Sites, and enter into confidentiality agreements with them where appropriate. Those service providers and data centers implement industry-standard measures to protect the security of the personal information we collect, such as SSL (Secure Socket Layers), firewalls, digital certificates, and encryption.

11. Your Privacy Rights

Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information. To make a request concerning your rights or if you have any other question, please contact us by sending an email to the address specified in the “Contact Us” section. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

12. Contact Us

If you have any questions about this Policy, or your dealings with this Site, please contact us by using one of the following communication channels.

• –Name of Chief Privacy Officer: Seokchan Lee
• –Email: privacy@krafton.com (Chief Privacy Officer) or DPO@pubg.com (Data Protection Officer)
• –Address: Yeoksam Center Field 231, Teheran-ro, Gangnam-gu, Seoul, Republic of Korea

SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC

In the event of a conflict between the supplemental Terms – Jurisdiction Specific that are relevant to your jurisdiction from which you are using our sites or apply to our company, and the rest of the Policy, the relevant jurisdiction’s Supplemental Terms – Jurisdiction Specific will supersede and control.

1. EEA, Switzerland, and the UK

If you are an EEA, Switzerland and UK residents, you may lodge a complaint with an EU/UK/EEA data protection authority for your country or region where an alleged infringement of applicable data protection law occurs.

Our representative in the EU is VeraSafe Netherlands BV, located at Keizersgracht 555, 1017 DR Amsterdam, The Netherlands. To contact them, please use the form available HERE.

Our representative in the UK is VeraSafe United Kingdom Ltd., located at 37 Albert Embankment, London SE1 7TL, United Kingdom. To contact them, please use the form available HERE.

• A)

  International Data Transfer

  If we transfer your data outside of the EEA to a country that is not recognized by the European Commission as ensuring an adequate level of data protection, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the latest standard contractual clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for personal data). You may ask for a copy of such appropriate measures by contacting us as set out in this Policy. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.

• B)

  Your Privacy Rights

  You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

2. India

If you are an Indian resident, you may have additional rights.

• A)

  Sensitive Personal Information

  We can collect your sensitive information(Proof ID number, etc.) when you apply to our company. We should collect or process your sensitive information under your consent.

B)

International Data Transfer

For Indian users, your personal information will be stored and processed on services located in India and Singapore. However, we may transfer your data to other countries(i.e. Korea) and/or regions to process recruitment and/or to meet legal requirements. In the event of transfer to another country or region, we will take steps to ensure that your information receives the same level of protection as if it remained in India.

3. Japan

A) Joint Use of Your Personal Data

We may use your personal data (definition thereof shall follow the same under then-effective Japanese Act on the Protection of Personal Information) jointly with our affiliates as follows.

B) International Data Transfer

If we transfer your data outside of Japan to a country that is not recognized by the Personal Information Protection Commission as establishing a personal information protection system recognized to have equivalent standards the same in Japan, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the reasonable standard measures following the requirements of Section 1 of Chapter 4 in Japanese APPI. You may ask for a copy of such appropriate measures by contacting us as set out in this Policy. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.

4. United States

• A)

  California

  If you are a California resident, please refer to our Privacy Notice for California Residents for more information concerning your rights.

B)

Nevada

If you are a Nevada resident, we do not sell your personal information that we collected, Nonetheless, if you are Nevada residents who purchased our game items or goods from us, you may submit a request to record your preference to opt out for the future.