Project Rogueteers

Closed Beta Test – US and Canada

Privacy Policy

Last Updated: [[  ] [LV1]2024

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 Closed Beta Test (“CBT”) of Project Rogueteers (“Service”). 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?	If you register to use the Service using Level Infinite Pass, then we will need some information from you to set this up. This includes an email address or password. We will generate an Open ID, which is an internal ID for your account. Depending on your use of the Service and the jurisdiction where you are based, you may also need to provide some additional information to help us set up your account. To maintain the smooth operation of the Service (which includes activities such from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information (such as IP address, connection speed, device specifications, as well as app- and OS-generated identifiers). If you choose, you can provide other information to personalise your experience of the Service or enable Service features. This includes language or location. 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.	More Information.
How will we use your information?	We use your information to set up your account, enable you to use the Service, localise the Service experience, enable interaction between users of the Service, save your progress, ensure the safe and secure operation of the Service, address bugs, optimise and improve the Service, protect users, monitor our marketing initiatives, resolve user queries, and to comply with our legal obligations and enforce our legal rights.	More Information.
Who do we share your information with?	We might use third parties and work with our affiliates to help us deliver the best possible experience. 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). 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.	More Information.
Where do we process your information?	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. We have servers for the Service in Singapore and the United States. We also have support, engineering and other teams who may support the Service, including from Singapore and the United States.	More Information.
How long do we keep your information?	Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Service, or 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.	More Information.
How can I exercise my rights over my information?	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.	More Information.
How will we notify you of changes?	Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.

Welcome to Project Rogueteers!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the Closed Beta Test (“CBT”) of Project Rogueteers (the “Service”), 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 projectr_dpo@levelinfinite.com

1.                Children

Children must not use the Service for any purpose.

By children, we mean users under the age of 13 years old in relation to Canada and the United States; or in the case of a region where the minimum age for processing personal information differs, such different 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.

2.                How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

Personal Information	Use	Legal Basis (where applicable)
Information you provide to us (either directly or through a third party)
Login via Level Infinite Pass: UID, token, email address, password	We use this information to allow you to register and create your account for the Service in accordance with your request, log in to the Service and participate in game activities and receive notifications of the Service.	Necessary to perform our contract with you to provide the Service.
Nickname	We use this information to create your account for the Service in accordance with your request.	Necessary to perform our contract with you to provide the Service.
Region location (manually selected by you)	We use this information to: set up your use of the Service on a regional server; and improve gameplay. [IPDP2]	Necessary to perform our contract with you to provide the Service.
Information generated as part of the Service
IP address, country/region	We use this information to allow you to use the Service and connect to our servers.	Necessary to perform our contract with you to provide the Service.
Anti-cheat information: Game logs (account information), device information (gameplay data, location information, device information, identity verification information), Open ID, nickname, IP address, user generated text content	We use this information for anti-cheating purposes, including to detect and observe cheating behaviours and monitor the presence and operation of suspected cheating activity or anomalies.	It is in our legitimate interest to use this information to detect and prevent cheating in the Service.
Diagnostic and crash reporting information: OpenID, IP address, MAC address,[IPDP3] operating system, CPU, GPU, memory, resolution, network status, process name, crash time, and crash dump	We use this information for diagnostic and crash reporting, and identifying, analyzing and resolving issues such as crashes and latency issues.	It is in our legitimate interest to optimize your experience in the Service.
Performance monitoring and analysis information: OpenID, IP address, SDK version, system time, system startup time, network status, PC hardware information (OS, CPU, GPU, screen resolution), client performance data (CPU usage, GPU usage, memory usage, FPS)	We use this information for performance monitoring and analysis.	It is in our legitimate interest to optimize your experience in the Service.
Data access support information: Open ID, nickname, game level, game server area ID, item ID and counts, mail ID, reg time, login time, logout time, online status, ban status and reasons	We use this information to allow for real-time data access and operation between various operating systems.	Necessary to perform our contract with you to provide the Service.
Game runtime data information: Server ID, System time, account information (OpenID, nickname), game level, gameplay statistics	We use this information to process and store your game runtime data.	Necessary to perform our contract with you to provide the Service.
Data analysis and reporting information: Server ID, system time, system startup time, network status, account information (Open ID, nickname), game level, PC hardware information (OS, CPU, GPU, screen resolution), client performance data (CPU usage, GPU usage, memory usage, FPS), IP address, gameplay statistics	We use this information to better undrestand our players’ gaming behaviours and to monitor the success of our advertising campaigns.[IPDP4]	It is in our legitimate interest to optimize your experience in the Service.
Voice chat information: Open ID, system time, IP address, MAC address, SDK version, Network Type	We process this information to facilitate your real-time voice chat with users. We also process and review this information if we suspect any inappropriate behaviour.   We do not store this information on our servers.	Necessary to perform our contract with you to provide the Service.
Text chat information: Open ID, text chat data	We process this information to provide you with the functions of lobby chat (public text chat, team chat and message chat (private text chat).	Necessary to perform our contract with you to provide the Service.
Survey information: SteamID, Open ID, email, nickname, game habits and preferences, social media history and preferences, and any other responses you provide as part of the survey	We use this information to better understand our users and to improve the Service.	We collect and use this information with your consent.
Customer Support:  Game account and contact information (including your nickname, profile picture, open ID, country selected by you during registration, login channel, social media account, mobile phone, email address, registration time); Login status verification information; Device information; Game data: Game character information (including your role name and role ID, game data and records, frequency of playtime, game history), and in-game data (including items, purchase and top-up information, penalties, activities, game match data, in-game friends); Customer service log data (including Open ID, ticket date, type of request); Feedback on steam store; Any other details/information (including any documents/media) that you choose to provide to us as part of your ticket, query or review	We use this information to improve our services and provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the Service.

 

3.                How We Store and Share Your Personal Information

We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Service in Singapore and the United States. The servers applicable to your use of the Service may depend upon your location. We also have support, engineering and other teams who may support the Service, including from Singapore and the People’s Republic of China.

 

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. 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:
  • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • 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.

4.                The Security of Your Personal Information

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.

 

5.                Data Retention 

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.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
Login via Level Infinite Pass   Data analysis and reporting information Customer Support	Stored for the duration of the Service, or deleted within 30 days if you request for account deletion or the Service is shut down.
Anti-cheat information Diagnostic and crash reporting information Performance monitoring and analysis information Data access support information Game runtime data information Survey information	Stored for 30 days after the end of the CBT. Evidence of penalty will be stored for the lifetime of your use of the Service.
Voice chat information Text chat information	We do not store this.

 

6.                Your Rights

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). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, 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 as part of your account by sending us an email at projectr_dpo@levelinfinite.com .[IPDP5]

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 (e.g., survey information) or pursuant to our contract with you (e.g., account name), 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. You can access the personal information we hold about you by sending us an email at projectr_dpo@levelinfinite.com. [IPDP6]

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Service account. 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. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase 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 projectr_dpo@levelinfinite.com or using the contact details set out below, 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 projectr_dpo@levelinfinite.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 personalised advertising or marketing promotions from us when using the Service by contacting us at projectr_dpo@levelinfinite.com[IPDP7]

7.                Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: projectr_dpo@levelinfinite.com

Mailing Address:

Tencent International Privacy & Data Protection Centre

30 Raffles Place #19-01

Singapore

048622

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.

8.                Changes

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.

9.                Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

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.

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.

United States

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.

 

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, including sensitive personal information (denoted by *), from or about you or your device:

• Identifiers, such as your Open ID / user ID, IP address, device ID, device token, email address, and nickname. This information is collected directly from you and your device.
• Characteristics of protected classifications under California or federal law such as national origin or age. This information is collected directly from you in the context of being our consumer.
• Internet or other electronic network activity information, such as your information regarding your use of the Service, including level, score, date and time stamps of actions, log-in and clickstream data and other device information as described in the main Privacy Policy. This information is collected directly from you and your device.
• Geolocation information such as your region location when you set up your profile and choose to provide this information for the Service. This information is collected directly from you.
• Audio and visual information such as photos shared in the Service, and audio messages. This information is collected directly from you.
• Professional or employment-related information such as your profession if you choose to provide it in a survey. This information is collected directly from you.[IPDP8]
• Account log-in information, including the username and password used to access your Service account.*
• Contents of your chat messages sent on Service*. This information is collected from your device, is only stored on your device, and is not retained by our servers.

 

We collect and disclose your personal information, including sensitive personal information, for the following purposes:

• To provide you with the Service, maintain your account, and deliver audio and text messages.
• To process surveys.
• To improve our services, including the functionality of the Service.
• For security and verification purposes, including to prevent and detect fraudulent activity.
• To address and remediate technical issues and bugs.

 

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 that we collect as described in Section 4 (How We Store and Share Your Personal Information).

 

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 for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.

 

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 this chart in the main portion of the Privacy Policy.

 

Rights under US State Laws:

 

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

 

• Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:
  • the categories of personal information about you that we collected;
  • the categories of sources from which the personal information was collected;
  • the business or commercial purposes for collecting personal information about you;
  • 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
  • the specific pieces of personal information we collected about you;
• Request to Delete. Request we delete personal information we collected about you;
• Request to Correct. Request we correct inaccurate personal information that we maintain about you;
• Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted advertising or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects; and
• Right to Non-Discrimination. 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 US State Laws.

 

How to Exercise Your Rights

 

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data 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 the following information from you: your first name, last name, address, phone number, date of birth and email address.

 

Depending on where you live, 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.

 

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

 

Questions

 

If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 8 (Contact).