Assassin’s Creed Jade Website
Privacy Policy
Last Updated: August 7th , 2023
Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.
Please note that this privacy policy (“Privacy Policy”) only applies to the website (the “Service”) for the game Assassin’s Creed Jade (the “Game”). If you use any other products or services, please refer to the privacy policy for that particular product or service.
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.
For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited.
SUMMARY
Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.
What information do we need to be able to provide the Service? | l If you register your interest in the closed beta test for the Game on the Service, we will need some information from you. This includes your LEVEL INFINITE PASS account information and recruitment survey responses. l If you are selected for the closed beta test for the Game, we use your email address to contact you about the closed beta test and your LEVEL INFINITE PASS account information to enable you to log in to play the Game. l If you sign up for game updates, we use your email address and registration channel information to send you such updates. l We use your IP address and registration channel information to understand our Service traffic and how visitors use the Service. l If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns. l We use cookies and other similar technologies to collect information about you when you use the Service, including your standard internet log information and details of visitor behaviour patterns. l We use email sending statistics to monitor the performance of our email sending activities. | |
How will we use your information? | l We use your information to enable you to use the Service, to participate in the recruitment survey, to assess your eligibility for the closed beta test for the Game, to enable you to participate in the test if you are selected, to provide you with game updates if requested, to understand how visitors use the Service, to maintain and improve our services, and to comply with our legal obligations and enforce our legal rights. | |
Who do we share your information with? | l We use third parties and work with our affiliates to help us deliver the best possible experience (such as for data storage, email delivery and performance analysis). l All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., to fulfil the purpose(s) described above). l In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information. | |
Where do we process your information? | l Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. l We have servers for the Service in Singapore. We also have support, engineering and other teams and service providers who may support the Service, including from Singapore and the United States. l We use a third-party service, Google Analytics, to collect cookies information. Google maintains servers around the world and your information may be processed on servers located outside of the country where you live. l For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent first or taking into account adequacy assessments. | |
How long do we keep your information? | l Unless otherwise required or permissible by applicable laws, we retain your information for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws. | |
How can I exercise my rights over my information? | l Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data. | |
How will we notify you of changes? | l Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements. |
Welcome to Assassin’s Creed Jade Website!
This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the website (the “Service”) for the game Assassin’s Creed Jade (the “Game”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.
Please note that this Privacy Policy only applies to the Service. If you use any other products or services please refer to the privacy policy for that particular product or service.
If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging how we process your personal information as described in this Privacy Policy.
For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited (“we”, “us”, “our”).
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at dpo_acm@proximabeta.com. We have representatives for data protection purposes listed here.
We use cookies, webhooks and other similar technologies (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. For more information about our Cookies policy, click here.
Children must not use the Service for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction).
By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.
Other than as provided above, we do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.
Region in which the user is located | Minimum age of the user |
Canada | 13 |
European Economic Area | 16 |
Türkiye | 18 |
United Kingdom | 13 |
United States | 13 |
This section provides more detail on the types of personal information we collect from you, and why.
For users who live in the European Economic Area, Türkiye or the United Kingdom, it also identifies the legal basis under which we process your data.
Personal Information | Use | Legal Basis (where applicable) |
Email address (processed by LEVEL INFINITE PASS if you choose to log in via your LEVEL INFINITE PASS account and sign up for game updates) LEVEL INFINITE PASS’s privacy policy can be found at: https://account.levelinfinite.com/privacypolicy.html | If you sign up for game updates, we use this information to send you such updates. | To the extent applicable and permissible in your region, it is in our legitimate interest to provide you with game updates. Otherwise, we collect this information with your consent. |
Recruitment survey information: LEVEL INFINITE PASS account information (email address and Open ID) and recruitment survey responses (region location, age range, whether English is your native language, Assassin’s Creed series game experience, role-playing game experience, phone operating system (iOS or Android), phone model, email address associated with Apple ID or Google Play account) | We use this information to assess whether you are eligible to participate in the closed beta test for the Game. | We collect this information with your consent. |
If you are selected, we use the email address associated with your LEVEL INFINITE PASS account to contact you about the closed beta test. This will be processed by LEVEL INFINITE PASS. | Necessary to perform our contract with you to provide the closed beta test of the Game if you are selected. | |
If you are selected, we use the email address associated with your Apple ID or Google Play account to contact you about the closed beta test and to send you a link to download the Game for the closed beta test. | Necessary to perform our contract with you to provide the closed beta test of the Game if you are selected. | |
Your LEVEL INFINITE PASS account information is used to enable you to log in to play the Game if you are selected for the closed beta test. | Necessary to perform our contract with you to provide the closed beta test of the Game if you are selected. | |
Registration channel information: Open ID and registration channel | We use this information to: · send game updates that may be of interest to you, if you sign up for updates; and · understand how visitors use the Service. | It is in our legitimate interest to use this information to monitor the performance of, and to improve, our services. |
IP address | We use this information to understand our Service traffic and how visitors use the Service. | It is in our legitimate interest to use this information to monitor the performance of, and to improve, our services. |
Customer support information: email address (if you contact us via email), screenshots to illustrate problem (optional), any other information you provide to us, details of ticket, complaint and handling | We use this information to provide support and troubleshooting, such as addressing and remediating technical issues and bugs, and improve our services. | Necessary to perform our contract with you to support the Service. |
Cookies information (collected via Google Analytics) including the following: • your browsing behaviour while using the website, including time on the website (the total time spent on the website; the time spent on each page and in what order the pages were visited), what internal links were clicked (based on the URL of the next pageview) • user agent string • initial page inspection • geographic location • operating system information • browser information • device information including screen size • referring site • IP address | We use this information to maintain and monitor the performance of the Service and to improve the website and the services it offers to our visitors. Please refer to our Cookies Policy here for more details. | It is in our legitimate interest to use this information to monitor the performance of, and to improve, our services. |
Email sending statistics such as email opens | We use this information to monitor the performance of our email sending activities. | It is in our legitimate interest to use this information to monitor the performance of, and to improve, our services. |
We have servers for the Service in Singapore. We also have support, engineering and other teams who may support the Service, including from Singapore.
Only where necessary will we share your personal information with third parties. Situations where this occur are:
· Third parties that provide services in support of the Service, including Tencent Cloud, a provider of cloud services that stores information identified in this policy in Singapore, and Amazon Web Services, a provider of cloud email services who processes email addresses and email sending statistics in Singapore and the United States. We also use Google Analytics to collect cookies information. You may find more information on how Google Analytics processes and safeguards data here. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., for the purpose(s) described above).
· Companies within our corporate group who process your personal information solely for the purpose of providing the Service to you. All such group companies may only use your personal information in accordance with this Privacy Policy.
· Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
· Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
o detect, prevent or otherwise address security, fraud or technical issues; or
o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
· A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.
We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.
We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.
Personal Information | Retention Policy |
Email address (processed by LEVEL INFINITE PASS if you choose to log in via your LEVEL INFINITE PASS account and sign up for game updates) | Stored for the duration of your use of the Service and removed within 30 days if you request for deletion or if the Service is shut down. |
Recruitment survey information Registration channel information Email sending statistics | Stored until the completion of the closed beta test for the Game and removed within 30 days thereafter (unless you request for deletion, in which case such data is deleted within 30 days). |
IP address | Stored until the completion of the closed beta test for the Game and removed within 30 days thereafter (unless you request for deletion, in which case such data is deleted within 30 days). |
Customer support information | Stored until resolution of customer support case. |
Cookies information | Stored for 2 months by Google Analyics. |
Some jurisdictions’ laws grant specific rights to users of the Service. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.
You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). To exercise your rights, please contact us.
Access
You may have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available to us by contacting us at dpo_acm@proximabeta.com.
Portability
You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.
Correction
You may have the right to correct personal information we hold that is inaccurate. If you believe we hold any personal information about you and that information is inaccurate, please contact us.
Erasure
You may have the right to request that we delete personal information we hold about you by contacting us at dpo_acm@proximabeta.com. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case.
Restriction of Processing to Storage Only
You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
Objection
You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at dpo_acm@proximabeta.com, and we will consider your request.
Consent Withdrawal
To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at dpo_acm@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.
Announcements
We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.
Advertising
You may choose to stop receiving marketing promotions from us by contacting us at dpo_acm@proximabeta.com.
Please get in touch with us if you have any questions. You can reach us in the first instance at:
Email: dpo_acm@proximabeta.com
We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.
If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.
Jurisdiction | Representative | Address | Contact details |
EU | Proxima Beta Europe B.V. | Buitenveldertselaan 3-5 1082 VA Amsterdam | |
UK | Image Frame Investment (UK) Limited | Suite 1, 3rd Floor 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB | |
Türkiye | Özdağıstanli Ekici Avukatlık Ortaklığı. | Varyap Meridian Grand Tower ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul Türkiye Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-Service conduct, bans, investigations, civil or criminal complaints. |
SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS
Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.
California
This section applies to California residents covered by the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”). For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the CCPA and do not include information excluded from the CCPA’s scope.
Collection and Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information from or about you or your device:
· Identifiers, such as IP address, Open ID and email address. This information is collected directly from you, your device and from Level Infinite Pass if you use your Level Infinite Pass account to log in to the Service or sign up for game updates.
· Device information, such as operating system and device model as described in the main Privacy Policy. This information is collected directly from you.
· Game-related data, such as Assassin’s Creed series game experience and role-playing game experience as described in the main Privacy Policy. This information is collected directly from you.
· Communication data, such as your communications with customer support. This information is collected directly from you.
· Geolocation data such as your region location provided as part of your survey responses. This information is collected directly from you.
· Registration channel. This information is collected directly from you or your device.
· Cookies information (collected via Google Analytics cookies) as described in the main Privacy Policy. This information is collected directly from you or your device.
· Email sending statistics (collected via Amazon Web Services) as described in the main Privacy Policy. This information is collected directly from you or your device.
· Other information described in subdivision (e) of Section 1798.80, including information about your age range. This information is collected directly from you in the context of being our consumer.
We collect and disclose your personal information for the following purposes:
· To provide you with the Service and customer service.
· To assess eligibility for participation in the closed beta test for the Game.
· To contact you about the closed beta test if you are selected.
· To enable you to log in to play the Game if you are selected for the closed beta test.
· To provide you with game updates if you sign up for such updates.
· To maintain and monitor the performance of, and to improve, our services.
For additional information about what each type of personal information is used for, see Section 3 (How We Process Your Personal Information).
We disclose each of the categories of personal information to the following types of entities:
· Other companies within our corporate group who process your personal information in order to operate the Service.
· Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
· Regulators, judicial authorities and law enforcement agencies and other third parties where reasonably necessary to comply with a legal obligation; enforce our terms and conditions; detect and prevent fraud or security issues; and to protect ours and others’ rights, property or safety.
· Entities that acquire all or substantially all of our business.
In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the CCPA, and we have no knowledge of any sale or sharing of personal information of users under 16 years of age.
In addition, we do not use or disclose sensitive personal information about you.
Retention of Your Personal Information
The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see Section 6 (Data Retention).
Rights under the CCPA:
If you are a California resident and the CCPA does not recognize an exception that applies to you or your personal information, you have the right to:
· Request we disclose to you free of charge the following information covering the 12 months preceding your request:
o the categories of personal information about you that we collected;
o the categories of sources from which the personal information was collected;
o the purpose for collecting personal information about you;
o the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
o the specific pieces of personal information we collected about you;
· Request we delete personal information we collected from you, unless CCPA recognises an exception;
· Request we correct inaccurate personal information that we maintain about you; and
· Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.
We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
How to Exercise Your Rights
If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, by contacting us as specified in Section 8 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need you to provide certain information such as your region location, email address, or any other information necessary to verify your identity.
Under the CCPA, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.
Questions
If you have questions or concerns regarding this Privacy Policy, please contact us as specified in Section 8 (Contact).
Canada
If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as specified in Section 8 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.
France
Instructions for the processing of your personal data after your death. You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.
You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation, your heirs, or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.
When you wish to make such instructions, please contact us as set out in Section 8 (Contact).
Türkiye
You have legal rights, which are set forth in Article 11 of the Turkish Law on Personal Data Protection Law (“DPL”), in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):
· learn whether or not your personal data has been processed;
· request information about processing if your personal data has been processed;
· learn the purpose of processing of your personal data and whether they have been used accordingly;
· know the third parties in the country or abroad to whom personal data has been transferred;
· request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
· request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
· object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and
· demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.
In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:
Identity of the overseas recipient | Location of the recipient (or as otherwise stated in the recipient’s privacy policy) | Purposes of use of Personal Information by the recipient | Items of Personal Information to be provided |
Tencent Cloud | Singapore | Storage | All personal data collected |
Google Analytics | As stated in Google’s privacy policy, Google maintains servers around the world and your information may be processed on servers located outside of the country where you live. | Reporting on visitor interactions on our website | Cookies information |
Amazon Web Services | Singapore | Provision of cloud email services | Email address |
Singapore and the United States | Email sending statistics |
Virginia
This section applies to Virginia residents covered by the Virginia Consumer Data Protection Act (“VCDPA”). For purposes of this section, “personal data” and “sensitive personal data” have the meanings given in the VCDPA and do not include information excluded from the VCDPA’s scope.
If you are a Virginia resident and the law does not recognize an exception that applies to you or your personal data, you have the right to:
· request that we disclose to you the personal data that we collect, use, or disclose, and information about our data practices.
· request we delete personal data we collected from you, unless the law recognises an exception;
· request we correct inaccurate personal data that we maintain about you;
· be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the law.
We do not collect sensitive personal data about you. We also do not process personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
How to Exercise Your Rights
If you are a Virginia resident to whom the VCDPA applies, you may exercise your rights, if any, by contacting us as set out in Section 8 (Contact).
How to Appeal Decision on Your Request
If you would like to appeal a decision on your request to exercise any right you have under the VCDPA, you may contact us as set out in Section 8 (Contact).