Privacy Policy
Abstract
Abstract
XPINEXT places great importance on the protection of users' personal data. We collect, use, disclose, and process personal data in accordance with the principles of transparency and necessity under the Personal Data Protection Act B.E. 2562 (2019) (PDPA), for the purposes of providing services, improving our services, complying with applicable laws, and safeguarding users' rights as prescribed by law.
Introduction
1. Welcome to the services of XPINEXT ("XPINEXT", "we", "us", or "our").
Welcome to the services of XPINEXT ("XPINEXT", "we", "us", or "our"). XPINEXT places the highest importance on the protection of personal data and the privacy of all users, and is committed to complying with applicable laws and regulations relating to personal data protection. This Privacy Policy (the "Privacy Policy") explains how XPINEXT collects, uses, discloses, stores, transfers, and/or otherwise processes personal data of users who access or use XPINEXT applications, websites, games, and related services (collectively, the "Services"). The terms "user", "you", and "your" refer to any person who registers an account with, uses, or accesses the XPINEXT Services, whether in whole or in part. XPINEXT recognizes that the personal data you provide to us is important and entrusted to us. Accordingly, we are responsible for managing, protecting, and processing your personal data appropriately, securely, and in accordance with applicable laws.
2. "Personal Data" means any information relating to a natural person tha…
"Personal Data" means any information relating to a natural person that enables that person to be identified, directly or indirectly, whether from such information alone or in combination with other information that XPINEXT possesses or can reasonably access. Examples of Personal Data include display name, profile picture, email address, user identification number, login information, device information, and service usage information.
3. By accessing, using, or registering an account to use the XPINEXT Serv…
By accessing, using, or registering an account to use the XPINEXT Services, you acknowledge and agree that you have read, understood, and accepted the practices, conditions, and terms set out in this Privacy Policy, and you consent to XPINEXT collecting, using, disclosing, storing, transferring, and/or processing your Personal Data for the purposes and under the conditions set out in this Privacy Policy, to the extent permitted by applicable law.
4. If you do not consent to XPINEXT processing your Personal Data as desc…
If you do not consent to XPINEXT processing your Personal Data as described in this Privacy Policy, please refrain from accessing, registering for, or using the XPINEXT Services. XPINEXT may amend, modify, or update this Privacy Policy from time to time by notifying users through the application, website, or any other channel that XPINEXT considers appropriate. Your continued access to or use of the Services after the amended Privacy Policy becomes effective shall be deemed an acknowledgment and acceptance of such amended Privacy Policy.
5. This Privacy Policy shall be read together with the Terms of Service,…
This Privacy Policy shall be read together with the Terms of Service, privacy notices, consent forms, and any other documents or agreements relating to the collection, use, disclosure, storage, or processing of users' Personal Data by XPINEXT. Unless expressly stated otherwise, such documents shall be deemed incorporated into and form part of this Privacy Policy.
Personal Data We Collect and How We Collect It
Overview
XPINEXT collects, uses, discloses, and/or processes users' Personal Data only to the extent necessary for providing the Services, administering user accounts, developing and improving the Services, maintaining system security, preventing fraud, complying with applicable laws, and for other purposes described in this Privacy Policy. XPINEXT collects Personal Data in accordance with the principles of lawfulness, transparency, necessity, and proportionality under the Personal Data Protection Act B.E. 2562 (2019) ("PDPA"). We primarily collect data directly from users and, in certain cases, may receive data from third parties or other sources that are authorized to disclose such data to XPINEXT. The collection, use, disclosure, and processing of such Personal Data shall be carried out on an appropriate legal basis, including performance of a contract, compliance with legal obligations, the user's consent, XPINEXT's legitimate interests, or any other legal basis prescribed by applicable law.
1. User Information from Third-Party Applications
Where users register, log in, or connect their account through third-party services or social media platforms such as Facebook, Apple, or Google, XPINEXT may receive Personal Data from such providers in accordance with the user's privacy settings and the terms of the relevant platform. The information XPINEXT may receive includes, but is not limited to: XPINEXT will process such information only to the extent necessary for registration, login, authentication, service provision, and improvement of the user experience, based on an appropriate legal basis under applicable law
- First and last name
- Account name or display name
- Profile picture
- User ID
- Email address
- Login and authentication information
- Approximate location
- Gender
- Date of birth or age range
- Friend list or publicly available friend information
- Activity information on the platform
2. Personal Data Provided Directly by Users
XPINEXT may collect Personal Data that users provide directly when they register, create an account, log in, connect an account, configure account settings, respond to surveys, participate in activities, contact customer support, or otherwise use the Services. Such Personal Data may include, but is not limited to: Information submitted through forms, surveys, activities, or other XPINEXT contact channels Any other information voluntarily provided by the user to XPINEXT Such information may be used for the purposes of registering and administering user accounts, verifying identity, maintaining account security, providing and supporting the Services, communicating with users, operating activities and benefits, and improving the quality of the Services and the user experience.
- First and last name
- Username or in-game name
- Email address
- Age, date of birth, or age range
- Password or information used for authentication and account security
- Profile picture or other profile information selected by the user
3. Information Generated Through Use of the Services
XPINEXT may automatically collect information generated from users' use of the Services, including information created or produced by users during their use of the Services, in order to provide the Services appropriately, securely, and efficiently. Such information may include, but is not limited to: History of receiving, using, redeeming, or transferring Virtual Currency, Virtual Items, Point, benefits, or rewards within the Services System performance information, log data, and events related to user accounts Information relating to the detection and prevention of fraud, misuse, or violations of the Terms of Service XPINEXT may use such information to provide and administer the Services, maintain service security, detect and prevent fraud or improper use, analyze usage trends, measure service performance, develop, improve, and optimize games and Services, and comply with applicable laws and enforce XPINEXT's Terms of Service.
- Game progress or service usage progress
- Access history and in-service activity history
- Point, rankings, achievements, or in-game status information
- Usage data relating to features, activities, missions, or systems within the Services
4. Payment Information
Where users conduct transactions through third-party payment providers or platforms such as Google Play or other payment service providers, XPINEXT does not collect or store sensitive financial information such as full credit card numbers, bank account details, or payment information that is directly collected and processed by such providers. However, XPINEXT may receive certain information from such providers to the extent necessary for providing the Services, including but not limited to: XPINEXT will use such information only as necessary to process orders, provide Services to users, verify and confirm transactions, prevent fraud, and comply with applicable laws or requirements.
- Payer name
- Billing address
- Payment transaction reference number
- Transaction details and status
5. Disclosure of Information by Users
In general, XPINEXT does not provide functionality that allows users to publicly publish Personal Data within the Services. However, if XPINEXT provides functions in the future that allow users to share, display, or publish information to other users or third parties, users acknowledge and agree that information they choose to disclose may be visible, accessible, copied, or used by others. Users should exercise caution when disclosing their Personal Data. To the maximum extent permitted by law, XPINEXT shall not be liable for any use, disclosure, or action by others in relation to information voluntarily disclosed by users through such Service functions.
6. Contacting Customer Support
When users contact XPINEXT customer support, whether by email, contact form, or any other channel provided by XPINEXT, XPINEXT may collect relevant information to the extent necessary, including but not limited to: Such information will be used to provide assistance, investigate and resolve service issues, follow up on support matters, maintain account security, and improve the quality of the Services and the user experience.
- Name and contact information
- Email address
- User account information
- Communication history
- Usage information related to the issue or request submitted by the user
7. Information from Other Sources
XPINEXT may receive or collect Personal Data from external sources, including but not limited to third-party data providers, analytics providers, advertising networks, and business partners. XPINEXT may process such information together with information received directly from users for the purposes of providing the Services, improving service performance, analyzing usage behavior, presenting appropriate content and communications, preventing fraud, and maintaining system security. The processing of data from such sources shall be carried out on an appropriate legal basis and in accordance with the principles of necessity, proportionality, and applicable personal data protection measures.
Use and Disclosure of Personal Data
Overview
XPINEXT will use, disclose, and/or process users' Personal Data only to the extent necessary for providing the Services, administering user accounts, maintaining system security, preventing fraud, developing and improving the Services, communicating with users, complying with applicable laws, and for other purposes described in this Privacy Policy. XPINEXT will not use or disclose Personal Data beyond the purposes notified to users, unless consent has been obtained or such use or disclosure is permitted or required by law.
1. Purposes of Processing Personal Data
XPINEXT may use and process users' Personal Data for the following purposes:
- (a) To register, create, verify, and administer user accounts, including determining access rights to the Services.
- (b) To provide, operate, maintain, develop, and improve XPINEXT games, applications, websites, and Services, including management of Virtual Currency, Virtual Items, Point, benefits, and rewards within the Services.
- (c) To provide technical support, customer service, responses to inquiries, and resolution of issues relating to the use of the Services.
- (d) To maintain system security, prevent, detect, and take action in relation to fraud, misuse, violations of the Terms of Service, or activities that may cause harm to XPINEXT, other users, or third parties.
- (e) To communicate with users, send information, news, notifications, announcements, benefits, marketing activities, or appropriate content and advertisements, subject to applicable law.
- (f) To analyze data, prepare statistics, conduct research, develop, and improve the quality, performance, and user experience of the Services, including marketing analytics and marketing activities.
- (g) To comply with laws, orders of government agencies, regulatory authorities, or legal processes, and to establish, exercise, defend, or enforce XPINEXT's legal rights.
2. Disclosure of Personal Data to Third Parties
XPINEXT may disclose or share users' Personal Data with third parties, partners, service providers, or data processors to the extent necessary for providing and operating the Services and for the purposes described in this Privacy Policy. Such disclosure shall be subject to the principles of necessity, proportionality, and lawfulness. XPINEXT will require recipients of Personal Data to implement appropriate personal data protection measures, including data processing agreements (DPAs) or equivalent arrangements where applicable. XPINEXT may disclose data to technology providers, analytics providers, marketing providers, payment providers, business partners, government agencies, or authorities legally empowered to receive such data.
3. User Consent
Where the collection, use, or disclosure of Personal Data cannot rely on another legal basis, XPINEXT will obtain the user's consent before or at the time of collecting the data. Such consent must be explicit, specific, and freely given by the user. Users have the right to withdraw their consent at any time. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal.
4. Aggregated and De-identified Data
XPINEXT may use or disclose user data in aggregated form or in a de-identified form for business analytics, research, service development and improvement, marketing, and statistical analysis. Such data will not identify any individual user, directly or indirectly, and shall not be considered Personal Data under applicable law.
5. Disclosure of Information to Other Players Within the System
Due to the nature of the Services as a gaming and social platform, certain user information may be disclosed to other users within the system in order to support service usage and interaction among players. Such information may include names or in-game names, profile pictures, and activity information within the Services. The display of such information shall be subject to system settings and/or privacy settings configured by users.
6. Use of Data for Advertising and Analytics
XPINEXT may use Personal Data and usage data to analyze behavior, measure performance, develop and improve service efficiency, and provide content, advertisements, or offers that are appropriate to users. XPINEXT may use advertising networks or external partners for such purposes. Where applicable law requires consent, XPINEXT will obtain users' consent before processing data for personalized advertising.
7. Disclosure of Information to External Service Providers
XPINEXT may disclose Personal Data to external service providers that operate on behalf of the company to support the Services, such as hosting services, cloud systems, analytics services, payment systems, and customer support. Such providers will receive information only to the extent necessary for their duties and will be subject to confidentiality and personal data protection obligations. They shall not use such data for purposes other than those specified by XPINEXT.
8. Sale, Transfer, or Business Restructuring
In the event of a merger, acquisition, business sale, transfer of rights, or transfer of all or part of XPINEXT's assets, users' Personal Data may be transferred to the person or legal entity involved in such transaction. XPINEXT will implement appropriate measures to protect Personal Data and will notify users as required by applicable law.
Users' Rights to Access, Correct, and Manage Personal Data
Overview
XPINEXT respects the rights of data subjects under personal data protection laws and provides users with the opportunity to access, correct, delete, restrict, or object to the processing of their Personal Data as provided by law. XPINEXT may require users to verify their identity before processing any request for data security purposes.
1. Withdrawal of Consent
Users have the right to withdraw consent previously given to XPINEXT for the collection, use, or disclosure of Personal Data at any time by submitting a request through the channels designated by XPINEXT. XPINEXT will process such requests in accordance with applicable laws. However, withdrawal of consent shall not affect the lawfulness of processing carried out before the withdrawal. In certain cases, withdrawal of consent may result in users being unable to use some or all of the Services.
2. Access to and Request for Personal Data
Users have the right to request access to and obtain a copy of Personal Data collected, used, or disclosed by XPINEXT, as well as to request details regarding the processing of such Personal Data. XPINEXT may require users to provide evidence to verify their identity before processing the request and will respond within the period prescribed by law.
3. Correction of Personal Data
Users have the right to request correction of their Personal Data so that it is accurate, up to date, and complete. If any information is inaccurate or incomplete, users may submit a request through the channels designated by XPINEXT or make corrections through the Service system. XPINEXT may refuse a request where correction cannot be carried out under applicable law or for technical reasons.
4. Deletion, Suspension, or Restriction of Data Use
Users have the right to request that XPINEXT delete, destroy, or de-identify their Personal Data, and to request suspension or restriction of the use of Personal Data in certain circumstances as provided by law. However, XPINEXT may refuse such a request where it is necessary to retain the data for compliance with law, dispute resolution, or the exercise of legal rights.
5. Right to Object to Processing
Users have the right to object to the processing of Personal Data in certain cases, particularly processing for personalized marketing or behavioral analytics. XPINEXT will consider such requests and act in accordance with applicable law unless there are overriding legitimate grounds.
6. Channels for Exercising User Rights
Users may submit requests to exercise the rights described in this section through the channels designated by XPINEXT, such as the Help Center or contact channels specified in this Privacy Policy. XPINEXT may request additional information to verify identity before proceeding and will consider and respond within the period prescribed by law.
Children's Policy
Children's Policy
XPINEXT recognizes the importance of protecting minors' Personal Data and complies with the requirements under personal data protection laws. XPINEXT does not intend to collect, use, or disclose Personal Data of persons under 20 years of age who have not reached legal age, unless explicit consent has been obtained from a person with parental authority or a lawful guardian. Where a user is under 20 years of age, the user must obtain consent from the person with parental authority before providing Personal Data to XPINEXT and before using the XPINEXT Services. If XPINEXT becomes aware or has reasonable grounds to believe that Personal Data of a minor has been collected, used, or disclosed without consent from the person with parental authority, XPINEXT will promptly delete, destroy, or de-identify such data, unless retention is required by law.
Personal Data Security Measures
Overview
XPINEXT implements appropriate technical and organizational measures to safeguard Personal Data and prevent unauthorized access, use, modification, disclosure, or destruction. Such measures are designed to correspond to the level of risk, nature of the data, and relevant industry standards. XPINEXT uses appropriate security measures, such as encryption, role-based access controls, and infrastructure security systems, to prevent unauthorized access to data. Users are responsible for maintaining the security of their own accounts, including keeping passwords confidential and not disclosing login information to third parties. If unauthorized account use occurs, users should notify XPINEXT immediately.
1. Disclosure Required by Law
XPINEXT may disclose users' Personal Data where necessary under applicable law, orders of government agencies, or legal processes, or where there are good-faith grounds to believe that such disclosure is necessary to prevent, stop, or address acts that may cause harm, fraud, or danger to the safety of individuals or the public.
2. Cross-Border Transfer of Data
XPINEXT may need to transfer or store users' Personal Data in systems or servers located outside the country for the purpose of providing the Services. XPINEXT will ensure that the destination country or recipient maintains an adequate level of personal data protection or implements appropriate safeguards as required by law, including contracts or obligations relating to personal data protection where necessary.
3. Data Retention Period
XPINEXT will retain users' Personal Data only for as long as necessary for the purposes described in this Privacy Policy or as required by applicable law. When retention is no longer necessary, XPINEXT will delete, destroy, or de-identify the data using appropriate and secure methods.
4. Amendments to the Policy
XPINEXT may revise or amend this Privacy Policy from time to time to reflect changes to the Services, laws, or relevant practices. XPINEXT will notify users through appropriate channels, such as the website, application, or other communication channels, before such changes become effective.
Questions, Concerns, Complaints, and Contacting Us
Questions, Concerns, Complaints, and Contacting Us
If users have any questions, concerns, suggestions, or complaints regarding this Privacy Policy or XPINEXT's processing of Personal Data, users may contact XPINEXT by email at [email protected] or through any other channel designated by the company. XPINEXT will review, consider, and respond to user requests within a reasonable period as prescribed by applicable personal data protection laws. The company may request additional information to verify the user's identity before processing the request for the security of Personal Data.
Abstract
XPINEXT places great importance on the protection of users' personal data. We collect, use, disclose, and process personal data in accordance with the principles of transparency and necessity under the Personal Data Protection Act B.E. 2562 (2019) (PDPA), for the purposes of providing services, improving our services, complying with applicable laws, and safeguarding users' rights as prescribed by law.
1. Welcome to the services of XPINEXT ("XPINEXT", "we", "us", or "our").
Welcome to the services of XPINEXT ("XPINEXT", "we", "us", or "our"). XPINEXT places the highest importance on the protection of personal data and the privacy of all users, and is committed to complying with applicable laws and regulations relating to personal data protection. This Privacy Policy (the "Privacy Policy") explains how XPINEXT collects, uses, discloses, stores, transfers, and/or otherwise processes personal data of users who access or use XPINEXT applications, websites, games, and related services (collectively, the "Services"). The terms "user", "you", and "your" refer to any person who registers an account with, uses, or accesses the XPINEXT Services, whether in whole or in part. XPINEXT recognizes that the personal data you provide to us is important and entrusted to us. Accordingly, we are responsible for managing, protecting, and processing your personal data appropriately, securely, and in accordance with applicable laws.
2. "Personal Data" means any information relating to a natural person tha…
"Personal Data" means any information relating to a natural person that enables that person to be identified, directly or indirectly, whether from such information alone or in combination with other information that XPINEXT possesses or can reasonably access. Examples of Personal Data include display name, profile picture, email address, user identification number, login information, device information, and service usage information.
3. By accessing, using, or registering an account to use the XPINEXT Serv…
By accessing, using, or registering an account to use the XPINEXT Services, you acknowledge and agree that you have read, understood, and accepted the practices, conditions, and terms set out in this Privacy Policy, and you consent to XPINEXT collecting, using, disclosing, storing, transferring, and/or processing your Personal Data for the purposes and under the conditions set out in this Privacy Policy, to the extent permitted by applicable law.
4. If you do not consent to XPINEXT processing your Personal Data as desc…
If you do not consent to XPINEXT processing your Personal Data as described in this Privacy Policy, please refrain from accessing, registering for, or using the XPINEXT Services. XPINEXT may amend, modify, or update this Privacy Policy from time to time by notifying users through the application, website, or any other channel that XPINEXT considers appropriate. Your continued access to or use of the Services after the amended Privacy Policy becomes effective shall be deemed an acknowledgment and acceptance of such amended Privacy Policy.
5. This Privacy Policy shall be read together with the Terms of Service,…
This Privacy Policy shall be read together with the Terms of Service, privacy notices, consent forms, and any other documents or agreements relating to the collection, use, disclosure, storage, or processing of users' Personal Data by XPINEXT. Unless expressly stated otherwise, such documents shall be deemed incorporated into and form part of this Privacy Policy.
Overview
XPINEXT collects, uses, discloses, and/or processes users' Personal Data only to the extent necessary for providing the Services, administering user accounts, developing and improving the Services, maintaining system security, preventing fraud, complying with applicable laws, and for other purposes described in this Privacy Policy. XPINEXT collects Personal Data in accordance with the principles of lawfulness, transparency, necessity, and proportionality under the Personal Data Protection Act B.E. 2562 (2019) ("PDPA"). We primarily collect data directly from users and, in certain cases, may receive data from third parties or other sources that are authorized to disclose such data to XPINEXT. The collection, use, disclosure, and processing of such Personal Data shall be carried out on an appropriate legal basis, including performance of a contract, compliance with legal obligations, the user's consent, XPINEXT's legitimate interests, or any other legal basis prescribed by applicable law.
1. User Information from Third-Party Applications
Where users register, log in, or connect their account through third-party services or social media platforms such as Facebook, Apple, or Google, XPINEXT may receive Personal Data from such providers in accordance with the user's privacy settings and the terms of the relevant platform. The information XPINEXT may receive includes, but is not limited to: XPINEXT will process such information only to the extent necessary for registration, login, authentication, service provision, and improvement of the user experience, based on an appropriate legal basis under applicable law
- First and last name
- Account name or display name
- Profile picture
- User ID
- Email address
- Login and authentication information
- Approximate location
- Gender
- Date of birth or age range
- Friend list or publicly available friend information
- Activity information on the platform
2. Personal Data Provided Directly by Users
XPINEXT may collect Personal Data that users provide directly when they register, create an account, log in, connect an account, configure account settings, respond to surveys, participate in activities, contact customer support, or otherwise use the Services. Such Personal Data may include, but is not limited to: Information submitted through forms, surveys, activities, or other XPINEXT contact channels Any other information voluntarily provided by the user to XPINEXT Such information may be used for the purposes of registering and administering user accounts, verifying identity, maintaining account security, providing and supporting the Services, communicating with users, operating activities and benefits, and improving the quality of the Services and the user experience.
- First and last name
- Username or in-game name
- Email address
- Age, date of birth, or age range
- Password or information used for authentication and account security
- Profile picture or other profile information selected by the user
3. Information Generated Through Use of the Services
XPINEXT may automatically collect information generated from users' use of the Services, including information created or produced by users during their use of the Services, in order to provide the Services appropriately, securely, and efficiently. Such information may include, but is not limited to: History of receiving, using, redeeming, or transferring Virtual Currency, Virtual Items, Point, benefits, or rewards within the Services System performance information, log data, and events related to user accounts Information relating to the detection and prevention of fraud, misuse, or violations of the Terms of Service XPINEXT may use such information to provide and administer the Services, maintain service security, detect and prevent fraud or improper use, analyze usage trends, measure service performance, develop, improve, and optimize games and Services, and comply with applicable laws and enforce XPINEXT's Terms of Service.
- Game progress or service usage progress
- Access history and in-service activity history
- Point, rankings, achievements, or in-game status information
- Usage data relating to features, activities, missions, or systems within the Services
4. Payment Information
Where users conduct transactions through third-party payment providers or platforms such as Google Play or other payment service providers, XPINEXT does not collect or store sensitive financial information such as full credit card numbers, bank account details, or payment information that is directly collected and processed by such providers. However, XPINEXT may receive certain information from such providers to the extent necessary for providing the Services, including but not limited to: XPINEXT will use such information only as necessary to process orders, provide Services to users, verify and confirm transactions, prevent fraud, and comply with applicable laws or requirements.
- Payer name
- Billing address
- Payment transaction reference number
- Transaction details and status
5. Disclosure of Information by Users
In general, XPINEXT does not provide functionality that allows users to publicly publish Personal Data within the Services. However, if XPINEXT provides functions in the future that allow users to share, display, or publish information to other users or third parties, users acknowledge and agree that information they choose to disclose may be visible, accessible, copied, or used by others. Users should exercise caution when disclosing their Personal Data. To the maximum extent permitted by law, XPINEXT shall not be liable for any use, disclosure, or action by others in relation to information voluntarily disclosed by users through such Service functions.
6. Contacting Customer Support
When users contact XPINEXT customer support, whether by email, contact form, or any other channel provided by XPINEXT, XPINEXT may collect relevant information to the extent necessary, including but not limited to: Such information will be used to provide assistance, investigate and resolve service issues, follow up on support matters, maintain account security, and improve the quality of the Services and the user experience.
- Name and contact information
- Email address
- User account information
- Communication history
- Usage information related to the issue or request submitted by the user
7. Information from Other Sources
XPINEXT may receive or collect Personal Data from external sources, including but not limited to third-party data providers, analytics providers, advertising networks, and business partners. XPINEXT may process such information together with information received directly from users for the purposes of providing the Services, improving service performance, analyzing usage behavior, presenting appropriate content and communications, preventing fraud, and maintaining system security. The processing of data from such sources shall be carried out on an appropriate legal basis and in accordance with the principles of necessity, proportionality, and applicable personal data protection measures.
Overview
XPINEXT will use, disclose, and/or process users' Personal Data only to the extent necessary for providing the Services, administering user accounts, maintaining system security, preventing fraud, developing and improving the Services, communicating with users, complying with applicable laws, and for other purposes described in this Privacy Policy. XPINEXT will not use or disclose Personal Data beyond the purposes notified to users, unless consent has been obtained or such use or disclosure is permitted or required by law.
1. Purposes of Processing Personal Data
XPINEXT may use and process users' Personal Data for the following purposes:
- (a) To register, create, verify, and administer user accounts, including determining access rights to the Services.
- (b) To provide, operate, maintain, develop, and improve XPINEXT games, applications, websites, and Services, including management of Virtual Currency, Virtual Items, Point, benefits, and rewards within the Services.
- (c) To provide technical support, customer service, responses to inquiries, and resolution of issues relating to the use of the Services.
- (d) To maintain system security, prevent, detect, and take action in relation to fraud, misuse, violations of the Terms of Service, or activities that may cause harm to XPINEXT, other users, or third parties.
- (e) To communicate with users, send information, news, notifications, announcements, benefits, marketing activities, or appropriate content and advertisements, subject to applicable law.
- (f) To analyze data, prepare statistics, conduct research, develop, and improve the quality, performance, and user experience of the Services, including marketing analytics and marketing activities.
- (g) To comply with laws, orders of government agencies, regulatory authorities, or legal processes, and to establish, exercise, defend, or enforce XPINEXT's legal rights.
2. Disclosure of Personal Data to Third Parties
XPINEXT may disclose or share users' Personal Data with third parties, partners, service providers, or data processors to the extent necessary for providing and operating the Services and for the purposes described in this Privacy Policy. Such disclosure shall be subject to the principles of necessity, proportionality, and lawfulness. XPINEXT will require recipients of Personal Data to implement appropriate personal data protection measures, including data processing agreements (DPAs) or equivalent arrangements where applicable. XPINEXT may disclose data to technology providers, analytics providers, marketing providers, payment providers, business partners, government agencies, or authorities legally empowered to receive such data.
3. User Consent
Where the collection, use, or disclosure of Personal Data cannot rely on another legal basis, XPINEXT will obtain the user's consent before or at the time of collecting the data. Such consent must be explicit, specific, and freely given by the user. Users have the right to withdraw their consent at any time. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal.
4. Aggregated and De-identified Data
XPINEXT may use or disclose user data in aggregated form or in a de-identified form for business analytics, research, service development and improvement, marketing, and statistical analysis. Such data will not identify any individual user, directly or indirectly, and shall not be considered Personal Data under applicable law.
5. Disclosure of Information to Other Players Within the System
Due to the nature of the Services as a gaming and social platform, certain user information may be disclosed to other users within the system in order to support service usage and interaction among players. Such information may include names or in-game names, profile pictures, and activity information within the Services. The display of such information shall be subject to system settings and/or privacy settings configured by users.
6. Use of Data for Advertising and Analytics
XPINEXT may use Personal Data and usage data to analyze behavior, measure performance, develop and improve service efficiency, and provide content, advertisements, or offers that are appropriate to users. XPINEXT may use advertising networks or external partners for such purposes. Where applicable law requires consent, XPINEXT will obtain users' consent before processing data for personalized advertising.
7. Disclosure of Information to External Service Providers
XPINEXT may disclose Personal Data to external service providers that operate on behalf of the company to support the Services, such as hosting services, cloud systems, analytics services, payment systems, and customer support. Such providers will receive information only to the extent necessary for their duties and will be subject to confidentiality and personal data protection obligations. They shall not use such data for purposes other than those specified by XPINEXT.
8. Sale, Transfer, or Business Restructuring
In the event of a merger, acquisition, business sale, transfer of rights, or transfer of all or part of XPINEXT's assets, users' Personal Data may be transferred to the person or legal entity involved in such transaction. XPINEXT will implement appropriate measures to protect Personal Data and will notify users as required by applicable law.
Overview
XPINEXT respects the rights of data subjects under personal data protection laws and provides users with the opportunity to access, correct, delete, restrict, or object to the processing of their Personal Data as provided by law. XPINEXT may require users to verify their identity before processing any request for data security purposes.
1. Withdrawal of Consent
Users have the right to withdraw consent previously given to XPINEXT for the collection, use, or disclosure of Personal Data at any time by submitting a request through the channels designated by XPINEXT. XPINEXT will process such requests in accordance with applicable laws. However, withdrawal of consent shall not affect the lawfulness of processing carried out before the withdrawal. In certain cases, withdrawal of consent may result in users being unable to use some or all of the Services.
2. Access to and Request for Personal Data
Users have the right to request access to and obtain a copy of Personal Data collected, used, or disclosed by XPINEXT, as well as to request details regarding the processing of such Personal Data. XPINEXT may require users to provide evidence to verify their identity before processing the request and will respond within the period prescribed by law.
3. Correction of Personal Data
Users have the right to request correction of their Personal Data so that it is accurate, up to date, and complete. If any information is inaccurate or incomplete, users may submit a request through the channels designated by XPINEXT or make corrections through the Service system. XPINEXT may refuse a request where correction cannot be carried out under applicable law or for technical reasons.
4. Deletion, Suspension, or Restriction of Data Use
Users have the right to request that XPINEXT delete, destroy, or de-identify their Personal Data, and to request suspension or restriction of the use of Personal Data in certain circumstances as provided by law. However, XPINEXT may refuse such a request where it is necessary to retain the data for compliance with law, dispute resolution, or the exercise of legal rights.
5. Right to Object to Processing
Users have the right to object to the processing of Personal Data in certain cases, particularly processing for personalized marketing or behavioral analytics. XPINEXT will consider such requests and act in accordance with applicable law unless there are overriding legitimate grounds.
6. Channels for Exercising User Rights
Users may submit requests to exercise the rights described in this section through the channels designated by XPINEXT, such as the Help Center or contact channels specified in this Privacy Policy. XPINEXT may request additional information to verify identity before proceeding and will consider and respond within the period prescribed by law.
Children's Policy
XPINEXT recognizes the importance of protecting minors' Personal Data and complies with the requirements under personal data protection laws. XPINEXT does not intend to collect, use, or disclose Personal Data of persons under 20 years of age who have not reached legal age, unless explicit consent has been obtained from a person with parental authority or a lawful guardian. Where a user is under 20 years of age, the user must obtain consent from the person with parental authority before providing Personal Data to XPINEXT and before using the XPINEXT Services. If XPINEXT becomes aware or has reasonable grounds to believe that Personal Data of a minor has been collected, used, or disclosed without consent from the person with parental authority, XPINEXT will promptly delete, destroy, or de-identify such data, unless retention is required by law.
Overview
XPINEXT implements appropriate technical and organizational measures to safeguard Personal Data and prevent unauthorized access, use, modification, disclosure, or destruction. Such measures are designed to correspond to the level of risk, nature of the data, and relevant industry standards. XPINEXT uses appropriate security measures, such as encryption, role-based access controls, and infrastructure security systems, to prevent unauthorized access to data. Users are responsible for maintaining the security of their own accounts, including keeping passwords confidential and not disclosing login information to third parties. If unauthorized account use occurs, users should notify XPINEXT immediately.
1. Disclosure Required by Law
XPINEXT may disclose users' Personal Data where necessary under applicable law, orders of government agencies, or legal processes, or where there are good-faith grounds to believe that such disclosure is necessary to prevent, stop, or address acts that may cause harm, fraud, or danger to the safety of individuals or the public.
2. Cross-Border Transfer of Data
XPINEXT may need to transfer or store users' Personal Data in systems or servers located outside the country for the purpose of providing the Services. XPINEXT will ensure that the destination country or recipient maintains an adequate level of personal data protection or implements appropriate safeguards as required by law, including contracts or obligations relating to personal data protection where necessary.
3. Data Retention Period
XPINEXT will retain users' Personal Data only for as long as necessary for the purposes described in this Privacy Policy or as required by applicable law. When retention is no longer necessary, XPINEXT will delete, destroy, or de-identify the data using appropriate and secure methods.
4. Amendments to the Policy
XPINEXT may revise or amend this Privacy Policy from time to time to reflect changes to the Services, laws, or relevant practices. XPINEXT will notify users through appropriate channels, such as the website, application, or other communication channels, before such changes become effective.
Questions, Concerns, Complaints, and Contacting Us
If users have any questions, concerns, suggestions, or complaints regarding this Privacy Policy or XPINEXT's processing of Personal Data, users may contact XPINEXT by email at [email protected] or through any other channel designated by the company. XPINEXT will review, consider, and respond to user requests within a reasonable period as prescribed by applicable personal data protection laws. The company may request additional information to verify the user's identity before processing the request for the security of Personal Data.