Privacy Policy

Last updated: 2022/07/05(Tue)

In order to ensure the highest quality of our services, 111 Percent Inc. (“we” or “us”) collects, stores, uses, share and protects information about you for our games on mobile devices, websites and related services (collectively “Services”). This Privacy Policy (“Policy”) describes how and when we collect, store, use and share your information.

Through this Policy, we regard your personal information as important and inform you of the purpose and method of our using the personal information provided by you and the measures taken by us for protection of those personal information. All our Services are governed by this Policy and by using or accessing a Service you give your consent to our collection, use and disclosure of the information as described in this Policy. Please do not install or use our Services if you do not agree to this Policy.

This Policy applies to any person that uses our Services, EXCEPT to a resident of the Republic of Korea. If you are using our Services in the Republic of Korea, please refer to our Privacy Policy offered in the Korean language.

Collection and Usage of Information
Game Play Data
Whenever you use our Services, we collect data about your interactions with our Services and with other users. The Information we collect may include Player ID, your progress in the game, IP address, device ID and/or other information that, we believe, is necessary to improve your user experience and maintain the quality of our Services.

User Device and Location
We may need your device and/or location information to provide troubleshooting solutions and to understand the usage trends of our customers. The information we collect may include nicknames, Player ID, unique device ID, OS, device model, advertising ID, location, IP, and/or other location-based information.

The data listed above can be used to track the content you access in connection with our Services and your online behavior or to deliver, target and improve our advertising and the Services. For more information on how to opt-out from personalized advertisements, see section “Opt-out of targeted advertising” below.

With your full consent, we may collect and process information on your precise location. We will use this information only to enhance the immediate game experience via functions like matching or similar.

Third-Party Login Services
When you log in to our Services using third-party login services (“Login Services”) such as Apple’s Game Center or Google+, the Login Services will provide you the option to share your personal information with us. Your personal information we receive via Login Services may include user ID, city, state or country you live. We may collect and record information through the Login Services in accordance with the policies and terms of that Login Services.

Information collected will be used to create your account, verify your identity when you log in, and allow you to play our games and use our Services. These Login Services may give you the option to post information about your activities on our games. If you want us to delete your data we receive from Game Center or Google+, please contact us at privacy@111percent.net.

Customer Support
When you contact our Game Operation Team, we may also collect your device information (such as your OS version and device model), location-based information, nicknames, Player ID or unique device ID, NAME, E-mail, and your service request information to provide proper solutions in troubleshooting situations.

Payment Information
We may collect certain payment information from you on behalf of our payment service providers when you purchase our products or Services, but this information is only temporarily stored so that it is unreadable by us. We do not collect or store any payment information from you.

Forum and Private Conversations
We may collect any information you provide in the public forum and private conversations for the purpose of improving user experience. The scope of a private conversation is limited to the exchange of ideas or messages using our Services. Chatting with other users in our games or privately messaging other users on our forum are examples of private conversations. Please note that any information you provide on the forum and private conversations may be read, collected, and used by others who access them. To request removal of your personal information from our community forum, please contact us at privacy@111percent.net

To improve your user experience, we may collect your email address when you register on the forum. The email address you provide will be mainly used to notify you about major policy changes or news regarding the usage of the forum. We may use the email address to contact you about your gaming experience with our games and notify you about company news and promotions. If you no longer wish to receive certain email notifications, you may opt-out any time by emailing us at privacy@111percent.net

Websites and Social Media Features
When you visit our websites, we may collect your personal information for the purpose of improving user experience on the websites. Such information may include your device OS, location, browser type, language, referring web address, your usage of the site, interests.

Our websites may include social media features, such as the Facebook Like button and widgets, such as Share button or interactive mini-programs that run on our websites. These features may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable the feature to function properly. Such social media features and widgets are either hosted by a third party or hosted directly on our websites. Your interactions with these features are governed by the privacy policies of the companies providing them.

Other Cases
We may acquire information from you through your access and participation in message boards, participation in surveys or contest through our Services. Certain information / personal information will be requested when you participate in some of our Services. Participation in these sweepstakes or contests is voluntary which means you have a choice whether or not to provide us with such information. The requested information may include contact information (name, address, etc.).

Disclosure of Your Information
We will not share your personal information without your consent except in the following conditions:

When you agree to share your information with third parties for their own marketing purpose.
We may disclose information about you as permitted by law or when we believe that release is appropriate to comply with the law, i.e.,
government request, applying our rights or protecting the rights, property, or safety of us or our users.
We may engage other companies or individuals to perform services on our behalf, i.e., Providing customer support.
We may share combined or anonymous information about you with business partners, advertisers, publishers, and other third parties.
We may also share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. You will be notified via email and/or notified on our site of any change in ownership or additional users of your personal information.

Transfer of Information Overseas
To maintain the quality and stability of our Services globally, your information may be transferred internationally. Data protection laws may vary depending on the country and may not correspond to those of your country. We guarantee the protection of your personal information as explained in our Policy. We will take all necessary privacy measures applicable in the country or territory to protect your information, but the country or territory may not have the equivalent protection standards of the European Commission's Adequacy Decision.

Our games use international cloud services. Therefore your information may be transferred to servers in the U.S. (Google Inc.) to store nicknames, Player ID, unique device ID, OS, device model, advertising ID, location, IP, and/or other location-based information. Also, the above-mentioned information may be transferred to the Republic of Korea, where our headquarters is located. Your personal information will be stored until you choose to delete your account.

Our cloud service partner: Google Inc. (https://firebase.google.com/support) Our Services use real-time database synchronization to transfer user information globally, therefore you will not be able to use our Services without agreeing to our Policy.

Cookies and Similar Technologies
We may collect collective and impersonal information through cookies and other similar technologies. Cookies are small text files of information sent by the web server used for the operation of an application to your device to be stored within the device memory. These functions are used for evaluating, improving Services and setting-up users’ experiences so that much improved Services can be provided by us to you.

The items of cookies to be collected by us and the purpose of such collection are as follows:
l Required Cookies: We use security-based cookies to ensure the security of our services. We may, among other things, use the information obtained from these cookies to identify possible fraudulent or abuse activities, enforce our Terms of Service and protect the safety of our users. These cookies are mandatory and cannot be blocked if you wish to use our services.

l Performance and Functional Cookies: We use analytics and investigation cookies to collect information about how the users use our services, including the total number of users who use our Services and the type of devices they use. We may use this information to create reports of aggregated and anonymized information and to assist in improving our Services. We also use feature tracking cookies to collect information about how our services are performed. We may use such information to create reports and improve our Services.

l Advertising Cookies: We use advertising cookies to personalize the advertisements displayed to you on our Services and on third party websites and other services.

Some parts of our Services are provided by third-party service providers, who may collect and record information about your use of our Services. Additionally, other companies that place advertisements on our websites, games and/or applications may collect information about you when you view or click on their advertising through the use of cookies. We cannot control the activities of such third parties and cannot guarantee that they will adhere to the privacy and security practices same or similar to ours. You should contact them directly if you have any questions about their use of the information that they collect.

Third Party Name : (Privacy Policy)
Firebase : https://firebase.google.com/support/privacy
Appsflyer : https://www.appsflyer.com/legal/privacy-policy/
Facebook : https://www.facebook.com/ads/manage/audiencenetwork/publishertos/
MoPub : https://www.mopub.com/en/legal/privacy
Google AdMob : https://policies.google.com/privacy?hl=en
Unity Ads : https://unity3d.com/legal/privacy-policy
Vungle : https://vungle.com/privacy/
AppLovin : https://www.applovin.com/privacy/
Adcolony : https://www.adcolony.com/privacy-policy/
MOLOCO : https://www.molocoads.com/en/privacy-policy
Twitter : https://twitter.com/en/privacy
Tiktok : https://www.tiktok.com/legal/privacy-policy-us?lang=en

Security of User Information
We follow generally accepted industry standards and maintain reasonable safeguards to attempt to ensure the security, integrity, and privacy of the information in our possession. As further security measures, we implement the following technical and managerial safeguards to ensure that any personal information of users we handle is secure from loss, leaks, or damage:

Improving Network Security - We implement various technical measures to prevent the leakage of your personal information by unauthorized access to its network via hacking, computer viruses, etc., and continuously monitors network access. In addition, to ensure the security of communications between its server and database, we use strong encrypted communication methods.
Conduct Security Training and Designation of Privacy Officer - We conduct regular security training for our employees on the protection of your personal information. Furthermore, we have designated a privacy officer to develop expertise in the handling of your personal information and to minimize the risk of information leakage.

Restrict Access and Storage - The location in which the handling and storage of personal information are performed has been designated as a secure area and access thereto has been restricted to personnel with the requisite authority. Documentation, storage mediums, and electronic records containing personal information are stored in a location equipped with a locking device or on a computer with restricted access.

Information Retention
We will retain your Personal Information for as long as your account is active or as needed to provide you services. If you no longer want us to use your information or wish to cancel / delete your account, please contact us at privacy@111percent.net.
If you contact our Customer Support, your data such as nicknames, Player ID, unique device ID, OS, game version & data will be transferred to the USA (Google Inc.). This information is collected in order to provide the support and will be permanently erased 3 years after the support request is concluded.

Opt-out of targeted advertising
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting "Limit Ad Tracking" (Apple iOS) or "Opt-out of interest-based ads" (Android).

Access to Personal Information
If there is a change to your personal information, or if you no longer wish to use our Services, you may edit, update, or delete your information by making the change within your account settings or by contacting us at privacy@111percent.net. We will provide you with a copy of your personal information in an electronic format upon request.

Your Privacy Rights
You may have the following rights:

Right of access: You have the right to obtain confirmation from us as to whether or not we process personal information from you and you also have the right to at any time obtain access to our personal information stored by us. To exercise this right you may at any time contact us as at privacy@111percent.net. You can also access the information you provided in the setting.
Right to rectification of your personal information: If we process your personal information, we shall endeavor to ensure by implementing suitable measures that your personal information is accurate and up-to-date for the purposes for which your personal information was collected. If your personal information is inaccurate or incomplete, you have the right to obtain the rectification of such information. To exercise this right you may at any time contact us as at privacy@111percent.net. You can also access the information you provided in the setting.
Right to erasure of your personal information or right to restriction of processing: You may have the right to obtain the erasure of your personal information or the restriction of processing of your personal information. To exercise this right you may at any time contact us at privacy@111percent.net
Right to withdraw your consent: If you have given your consent to the processing of your personal information, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal. To exercise this right you may at any time contact us at privacy@111percent.net.
Right to data portability: You may have the right to receive the personal information concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller. To exercise this right you may at any time contact us as at privacy@111percent.net.
Right to object: You may have the right to object to the processing of your personal information as further specified in this Policy.
Right to lodge a complaint with supervisory authority: You have the right to lodge a complaint with the Data Protection Authority (DPA). If you are an EU resident, you have the right to lodge a complaint with a data protection supervisory authority located in the European Union.
We do not carry out automated individual decision-making and profiling of your personal data.

Contact us
If you have any questions about our protection of your personal information, or if you have any requests for resolving issues regarding your personal information, please contact us at the information below:
Name of the controller: 111 Percent Inc.
Address: 111 Percent Inc., Gangnam finance Tower 33F, 152, Teheran-ro, Gangnam-gu, Seoul, Republic of Korea.
Email: privacy@111percent.net.

Collection and Use of Children’s Personal Information
We do not knowingly collect any personal information from anyone under the age of 13 (under the age of 16 in Europe), unless consent is given by a parent or legal guardian. If you are under 13 years of age (16 in Europe), please do not send us any information about yourself, and you should not use or attempt to use our Services. Some of our Services have age restrictions which may vary depending on countries, regions, OS, platforms, etc. If you are under the applicable age restrictions, please do not send us any information about yourself and you should not use or attempt to use our Services.

In the event we learn that we have inadvertently gathered personal information from children under the age of 13 (16 in Europe), we will take reasonable measures to promptly delete such information from its records in a secure manner. If you believe that we may have any information from or about children under the age of 13 (16 in Europe), please let us know by sending us an email at privacy@111percent.net.

Please note that all persons under the age of majority are required in their respective jurisdictions to have a parent or guardian read and accept this Policy and the Terms of Service on their behalf. Parents are encouraged to supervise their children’s use of our Services and to become familiar with the types of content available through our Services. Parents should oversee their children’s use of e-mail and other online communications.

California Privacy Rights
This Section shall apply to California residents only. Under the California laws, California users have the right to request that we disclose what personal information we collect from you, to delete the information, to opt-out of the sale of your personal information, and the right not to be discriminated against for exercising one of your California privacy rights. We do not sell your personal information and do not discriminate you in response to privacy rights request.

Right to Opt-Out: We use and share your personal information only in accordance with this Policy. We do not believe this use and sharing is a sale under the applicable California laws. We have not sold your personal information in the last 12 months and we currently do not have any plans to sell your personal information in the future.
Shine the Light Law: We do not share your personal information with third parties for the purpose of direct marketing.
Do Not Track: California law requires us to inform you how we respond to web browser Do Not Track signals. Because there is no industry or legal standard for recognizing or honoring Do Not Track signals, we do not respond to Do Not Track signals at this time.
Exercising your rights: If you want to exercise your California privacy rights or if you have any questions regarding our practices, please e-mail us at privacy@111percent.net.

Data Protection Officer and Representative
We have designated the following persons as the Chief Privacy Officer and Personal Information Manager to remain responsible for responding to user inquiries regarding personal information and resolving any related complaints.
Name : Jonghwa Lee
Div. : Information Security Div.
E-mail : privacy@111percent.net

Changes to the Policy
We may amend this Policy from time to time to reflect improvements or any other changes to our business. We will try to inform you about any significant changes to this Policy, which we feel may disadvantage you in any material way. If you object to any of the changes you should immediately stop using our Services and close any account you may have with us.