Effective Date : April 9, 2025
VICTORY GAMES INC. (hereinafter referred to as the “Company”) values the protection of users’ personal information and complies with the relevant laws, including the “Act on Promotion of Information and Communications Network Utilization and Information Protection, etc.” This policy explains how personal information is used and what protection measures are taken.
1. Personal Information Collected and Methods of Collection
(1) Items Collected
① During the use of services or business processes, the following information may be generated and collected:
- Device information (model name, OS version, firmware version, device ID, etc.), IP address, cookies, and recent access location
- Records related to the use of location-based services
- Access time, service usage history, and misuse history
② When a payment is required during the use of free or paid services:
- Purchase history, gift card number, and other payment-related information
③ When requesting a refund or recovery of paid content:
- Email address, purchase records, and additional personal information (such as real name) to verify third-party purchases
(2) Collection Methods
- Through agreement procedures during service sign-up
- Through separate consent for promotions and events
- Automatically collected via partner platforms
- Voluntarily provided by users or upon the Company’s request during service use
2. Purpose of Collecting Personal Information
The Company uses collected personal information for the following purposes:
- To ensure communication channels for announcements and handling user complaints
- To respond to paid service inquiries, manage contract-related disputes, and provide customer support
- To inform users about new services and product launches
3. Provision and Sharing of Personal Information
(1) The Company does not provide or share users’ personal information with third parties, except in the following cases:
- When the user gives prior consent
- When required by law
(2) Personal information may be provided without user consent in the following cases:
- When needed for payment settlement
- When used for statistics, academic or market research in a way that anonymizes users
- When required by investigative authorities
4. Delegation of Personal Information Processing
The Company may delegate personal information processing to third parties to provide services. In such cases, the Company ensures that contractors securely process personal information in accordance with applicable laws.
5. Retention and Use Period of Personal Information
(1) In principle, personal information is destroyed immediately upon membership withdrawal. However, it may be retained for 3 months under internal policy to prevent misuse.
(2) If required by law or internal policies, information is retained as follows:
- Records of contracts or subscription withdrawal (5 years – E-commerce Act)
- Payment and goods supply records (5 years – E-commerce Act)
- Consumer complaint and dispute records (3 years – E-commerce Act)
- Identity verification records (6 months – Network Act)
- Visit logs (3 months – Communications Privacy Protection Act)
(3) Users may request to view retained personal information, which will be promptly provided.
6. Procedures and Methods for Destroying Personal Information
(1) Destruction Procedure
- Personal information is destroyed after achieving the collection purpose and a certain retention period, if required by law or internal policies.
(2) Destruction Method
- Electronic files: deleted by technical methods to prevent recovery
- Paper documents: shredded or incinerated
7. Permissions Used in the App
The app uses the following permissions:
① Read phone status: for third-party ad SDK recommendations
② Read logs: for game crash analysis
※ Permissions are not used without prior consent. Users may deny permissions when prompted by the system, but in that case, the feature may not function.
8. Rights of Users and Legal Guardians
① Users may exercise their rights through the service platform or the Company’s website.
② Users and legal guardians may view, modify, or delete their own or a minor’s personal information.
③ Personal information can be updated on the My Page section.
④ Requests can also be made via phone, email, or written request.
⑤ If correction is requested, the information will not be used or shared until corrected.
⑥ Upon account deletion, the personal information is destroyed and will not be used for other purposes.
9. Technical and Administrative Measures
The Company takes the following measures to prevent the leakage, theft, or alteration of personal information:
- Passwords are not collected
- Only a minimum number of staff handle data, and receive regular training
- A dedicated privacy protection organization monitors and responds to issues
※ The Company is not responsible for user-caused leaks (e.g., ID/password exposure) or network environment issues.
10. Personal Information Inquiries
For any questions about personal information or this policy, please contact:
Name: Privacy Manager
Email: contact@victorygamesinc.com
11. Miscellaneous
① When providing external links, users should review the privacy policy of the linked site.
② Users are responsible for inputting accurate personal information.
③ Users are also responsible for protecting others’ personal information.
12. Children’s Personal Information
The Company does not collect personal information from children without parental consent, except where permitted by applicable laws (e.g., COPPA, GDPR).
13. Notice of Policy Changes
If there are changes in laws, policies, or security technologies, the Company will notify users at least 10 days in advance, stating the reason and details of the change.
14. Transfer of Personal Information Outside the EU/EEA
The Company shares personal data with affiliates and partners outside the EU/EEA and ensures protection through Standard Contractual Clauses (SCCs) and additional safeguards (e.g., encryption, pseudonymization).
- Vendors outside the EU/EEA are also subject to additional technical safeguards.
- For details on cross-border transfers and safeguards, please contact the Company.
15. User Rights under the GDPR
Users may request access, correction, deletion, restriction, or objection to the processing of their personal data.
- No automated decision-making or profiling is conducted.
- Consent can be withdrawn at any time without affecting prior processing.
- Users can object to processing based on legitimate interests.
16. Contact
For inquiries related to this privacy policy, please contact us at:
📧 contact@victorygamesinc.com