Customer Center

STOVE Privacy Policy (Version at 29 August 2018)

STOVE Privacy Policy

Before (2018/04/30)

 

1. Why are you reading this?

 

This policy ("the Privacy Policy") sets out how we will use personal information and what measures we will take to protect personal information when we provide services (“our Service”) to individuals (“User” or “Member” or “you”).

For the purposes of applicable privacy laws, Smilegate Stove Inc. (“the Company” or “we”) of 344 Pangyo-ro, Bundang-gu, Seongnam-si, Gyeonggi-do, Korea is responsible for your personal information. It is important to us that we treat your personal information in accordance with relevant laws and regulations.

We may amend our Privacy Policy from time to time. If we do, we will let you know by posting a notice on our website 7 days prior to the amendments taking effect. If we are making significant changes to User's rights (e.g., collection and use of personal information, policy about providing information to a third party), we will endeavor to post this notice 30 days prior to the amendments taking effect. In addition, we may inform you of amendments via email or other communication channels.

Unless otherwise defined herein, all capitalized terms used herein shall have the same meaning as set forth in the Terms and Conditions of Service User of STOVE.

The latest version of our Privacy Policy can be found on our website at http://www.onstove.com.

2. Collection

1) What information do we collect?

① The following information is collected when a User signs up for our Service.

● Member: Stove Account Login Information (ID, Password, Nickname, Age)
● Connection with Facebook: e-mail address of Facebook account (ID), Stove Nickname
● Connection with Google: e-mail address of Google account (ID), Stove Nickname

② The following information may be collected while Members use our Service.

● PC games: service usage records, improper use records, login records, IP information, PC specifications information
● Mobile games: e-mail address (ID), service usage records, improper use records, payment records, login records, model name of devices with smart OS installed (tablet PC, smartphone, etc.), OS information, device identifier (UUID), advertising identifier (ADID)
● Mobile apps: model name of devices with smart OS installed (tablet PCs, smartphones, etc.), OS information, device identifier (UUID), advertising identifier (ADID)

③ The following information may be collected when a 1-on-1 inquiry is made.

● Member
l  Mandatory: Stove Account Login Information(ID)
l  Optional: nickname, PC specifications information

● Non-member
l  Mandatory: e-mail address

④ We may collect additional information for the following customer-related services, and if so, shall enter into a separate agreement with you for the collection and use of personal information.

● PC game: event participation, legal representative's agreement on payment, gameplay time selection, subscription to channeling services, marketing notifications (SMS, TM, etc.)
● Mobile game: event participation, marketing notifications (Push notification, SMS, etc.)

⑤ The following information may be collected when Users make payments for our Service.

● PC game
l Payment by mobile phones: date of birth, gender, mobile phone number, mobile carrier
l Payment by deposit without bankbook or by Internet banking: bank name, depositor’s name, purchaser’s name
l Coupon registration: e-mail address, name, date of birth, country code, IP information

l Payment by credit cards: card company name, installment period, card number, expiration date, purchaser’s name, confirmation number

● Mobile game
l Payment through market: market order number
l Coupon registration: coupon information

2) How do we collect information?

We collect information which you provide to us in the following circumstances:

■ when you sign up for our Service through our website or via your mobile device;
■ when you use our Service;
■ when you communicate with us over fax, telephone, email or other channels;
■ when you participate in our events; and
■ When it is provided to us by third parties including Facebook and Google where Users choose to share additional information with us.

3. Processing of Unique Identification Information

1) Unique Identification information includes resident registration number, passport number, driver's license number, and alien registration number.

2) We collect unique identification information for the following purposes, and collection of each requires us to enter into a separate agreement with you: 

① To impose tax and public utilities charges on prize winners; and
② When required by law.

Collected unique identification information shall not be used for purposes other than the purposes listed above, and shall be stored in an encoded format for safe management.

4. Use

We use the personal information we collect for the following purposes:

1) Providing our Service:

Fulfilling contracts for services;
Conducting payment settlement for the said services;
■ Providing contents;
■ Making purchases and payments;
■ Delivering packages;

■ Collecting fees; and
■ Protecting our business and interests (including investigating violations of our Terms and Conditions).

2) Member management:

■ User identification;
■ Protection from improper use or unauthorized use of our Service;
■ Confirmation of User's intention to sign up;
■ Age verification;
■ Processing user complaints;
Protecting the interests of Users, guests and third parties (including investigating violations of our Terms and Conditions);
Storing, maintaining and updating (including records for dispute settlement); and
Sending notifications.

3) Guest management

Handling complaints or providing customer support related to use of mobile services.

4) Marketing and advertisements

As permitted by law, sending notifications about new services, events, advertisements;
Using aggregated anonymous data to develop a better understanding of our customers, such that we may constantly improve our services and better meet user needs and expectations;
Providing service for Users depending on demographic characteristics; and
Creating statistics about Member's connection frequency or use of service.

5. Exceptions

If you live in the EU, please see section 15 below for the legal bases that we rely on to process your personal information.

We may process personal information that we have collected for additional purposes where:

① Users provide prior consent to those purposes;
② Relevant laws require us to do so or if legal authorities request it in accordance with the procedures and methods specified by law for investigation purposes; or

③ Information is needed for statistics generation, research, or market investigation purposes and that information is provided in a format from which Users cannot be identified.

We may also provide the personal information which we have collected to certain companies in accordance with the table below to improve our Service if you have given us your prior consent. In the event that we sell or buy any business assets, we may share your personal information with the prospective buyer or seller of such business or assets. If we or substantially all of our assets are acquired by a third party, personal information held by us about you will be one of the transferred assets. 

Information on Provision of Personal Information to Third Parties

① Mobile game

Provided To

Purpose of Provision

Personal Information Provided

Storage and Usage Period of Provided Information

Smilegate Megaport, Inc.

Provide game service

E-mail address (ID), login records, service usage records, device record

Until membership withdrawal or termination of service

Customer support

E-mail address

Stored for 3 years, then discarded

Sundaytoz, Inc

Provide game service

E-mail address (ID), login records, service usage records, device record

Until membership withdrawal or termination of service

Customer Support

E-mail address

Stored for 3 years, then discarded

6. Personal Information Management

To improve our Service, we share personal information with certain third party companies who specialise in personal information management, and help us ensure that the management of your personal information is in accordance with relevant laws. We currently share personal information with the companies listed in the table below who process it on our behalf.

Entrusted Companies

Purpose of personal data sharing

Smilegate Megaport, Inc.

System maintenance

SMS, EMS dispatch

Customer Support

Smilegate Entertainment, Inc.

Service support

7. Transferring Personal Information Overseas

The STOVE platform uses cloud services overseas to provide seamless services and boost User's convenience. The following section provides information on our arrangement to transfer personal information overseas. We will take appropriate steps to ensure that any international transfer of personal information is carried out in accordance with applicable privacy laws.

1) Personal information transferred outside the country due to use of overseas server (Amazon)

① Information transferred

● E-mail address, nickname, name, date of birth, legal representative's name and e-mail address, cookies, IP address, personal identifier (CI)

② Country, date/time and method

● Country: countries where Amazon's Global Cloud services are being provided (including Japan)
● Date/time: whenever you are using the STOVE service
● Method: transfer to servers in Global Cloud areas through a highly secured private network

③ Recipients

● Name: Amazon Web Services, Inc. (Person in charge: Stephen Schmidt)
● Address: 410 Terry Avenue North, Seattle, WA 98109-5210 / Tel: (206) 266-1000

④ Purpose of transferring

● To operate STOVE

⑤ Period of retention and usage

In principle, collected personal information is discarded promptly when the purpose of collection is reached. However, the following information is held for a specified period for the reasons below:

  • Member
    - Information retained: e-mail address, nickname, name, date of birth, legal representative's name and e-mail address, cookies, IP address, personal identifier (CI)
    - Retention period: until the date of membership withdrawal
  • Customer Support
    - Information retained: e-mail address, nickname
    - Retention period: 3 years from the date of receipt of inquiry (e.g., handling complaints and errors), 5 years from the date of receipt of inquiry regarding online payment in accordance with the Korean Act on the Consumer Protection in the Electronic Commerce Transaction, etc.

2) Personal information transferred to the Republic of Korea to be processed by Us

① Information transferred

● E-mail address, nickname, name, date of birth, legal representative's name and e-mail address, cookies, IP address, personal identifier (CI)

② Country, date/time and method

● Country: the Republic of Korea
● Date/time: whenever you are using the STOVE service
● Method: transfer to servers in Global Cloud areas through a highly secured private network

③ Recipients

● Name: Smilegate Stove, Inc. (the Company, Us)
● Address: 344 Pangyo-ro, Bundang-gu, Seongnam-si, Gyeonggi-do, Korea

④ Purpose of transferring

● To operate STOVE

⑤ Period of retention and usage

In principle, collected personal information is discarded promptly when the purpose of collection is reached. However, the following information is held for a specified period for the reasons below:

  • Member
    - Information retained: e-mail address, nickname, name, date of birth, legal representative's name and e-mail address, cookies, IP address, personal identifier (CI)
    - Retention period: until the date of membership withdrawal
  • Customer Support
    - Information retained: e-mail address, nickname
    - Retention period: 3 years from the date of receipt of inquiry (e.g., handling complaints and errors), 5 years from the date of receipt of inquiry regarding online payment in accordance with the Korean Act on the Consumer Protection in the Electronic Commerce Transaction, etc.

8. Retention

1) We store personal information for 30 days after the purpose for which personal information was collected has been satisfied, in order to handle customer complaints and dispute resolution such as unwilling withdrawal of membership as a result of hacking. After that 30 day period, the information will be destroyed permanently.

2) If we need to store User information for a different period of time due to commercial law or e-commerce customer protection law, we will do so. In this case, we will retain such personal information solely for the purpose of storage, and the duration of storage is as follows:

① Records of contract or withdrawal: 5 years
    (Reason for storage: the Korean Act on Consumer Protection in the Electronic Commerce Transactions, etc.)

② Records of payment and goods supply: 5 years
    (Reason for storage: the Korean Act on Consumer Protection in the Electronic Commerce Transactions, etc.)

③ Records of customer complaints and disputes: 3 years
    (Reason for storage: the Korean Act on Consumer Protection in the Electronic Commerce Transactions, etc.)

④ Marketing or advertisement records: 6 months
    (Relevant law: the Korean Act on Consumer Protection in the Electronic Commerce Transactions, etc.)

⑤ Website visiting history: 3 months
    (Reason for storage: Protection of Communications Secrets Act of Korea)

⑥ If we have notified you of or agreed upon a different time period: The period notified or agreed upon individually

 

9. Destruction methods

We will destroy the collected personal information promptly when the purpose of collection is fulfilled. The process is as follows:

1) Destruction process

When the storage purpose has been fulfilled, we will wait 30 days and then destroy information entered by the User for signing up for our Service, without delay in accordance with this policy and relevant law.

2) Destruction methods

① Personal information printed on paper shall be shredded or burned.

② Personal information stored in electronic files shall be removed using technology that permanently deletes the file without the possibility of restoration.

10. Your rights

If you live in the EU please see section 15 below for information about your rights.

1) Members can check or modify their personal information at any time, and may request membership withdrawal or removal of personal information if the Member does not agree with the way we process personal information. However, if personal information required for the provision of our Service is removed, the entire or part of our Service may not be available.

2) Members can check or modify personal information in the [Change Personal Information] menu within our Service. Also, Members can use the [Withdrawal] menu in Service to end the contract at any time, and personal information of the Member shall be removed when the contract is terminated. However, we may store the Member's personal information for a certain period under the circumstances listed in paragraph 5 below.

3) If a Member requests modification or removal of personal information, we will take the necessary actions promptly. Also, we may destroy personal information such as a Member's ID based on the terms and conditions of our Service and at the discretion of the Chief Privacy Officer.

4)  When a request for changing incorrect personal information is submitted, we will not provide or use the personal information until the information is properly corrected. Also, if incorrect information is already provided to a third party, the correct information will be notified to the third party without delay for prompt correction.

5)  We keep the personal information removed or deleted by Member's request in accordance with Section 8 (Retention) and does not allow viewing or using the stored information for other purposes.

11. Cookies

In order to provide customised services for Users, we use 'cookies' to collect your personal information. Cookies are bits of information that the server sends to the User's web browser or app, and are stored in your computer or device. These cookies may enable us to identify your computer or device, but we will not use this data to identify individual Users.

You may choose whether or not to enable cookies by changing the settings on your web browser or device. However, if you choose not to enable cookies, you may not be able to access certain services which we provide.

12. Security

We implement technical and managerial procedures to protect User's personal information from being lost, stolen, exposed, falsified, or damaged.

1) Technical measures

User's personal information is encoded in a way that is viewable by the User only, and changes of information can only be done by the User on the website or upon that User’s request.

To prevent leakage of User's personal information, we have set up devices that protect personal information from external attack, hacking, and unauthorized access. Also, all personal information is safely transferred into our network system using a secured network system. In the case of the servers containing our User's personal information, we ensure that these servers are not directly connected to external internet lines, and that we have all available technical devices in place to ensure security is protected.

③ We have a backup system for the system and data to handle unexpected issues which may arise.

④ We regularly update our anti-virus software programs to prevent damage caused by computer viruses.

2) Managerial measures

① We restrict access to your personal information to a limited number of employees who:

are engaged in marketing services directly to Users;
work in the personal information management department or engage in work related to personal information management; or
are required, out of necessity, to process personal information.

② We provide regular training for employees on new security technologies and protection of personal information, and regularly audit personal information management status and compliance by employees. We use our best endeavors to fix problems when a problem is discovered.

③ When employees are involved in handing over their duties, the transition process is carried out in a strictly confidential manner. We clearly notify employees of their responsibilities or consequences for incidents that might happen as a result of information leakage after joining and leaving the Company.

④ The Company's personal information processing is strictly limited to the relevant administrators, and we provide them with separate passwords that are periodically updated. We also conduct regular training for such employees to enhance our personal information protection practices.

We hold no responsibility for incidents or leakage of personal information resulting from a User's mistake or inherent risk factors of the Internet. Users are responsible for keeping their accounts and passwords secure to protect personal information.

13. Users in California

1) Specific rights may be granted to Users residing in California. We abide by the California Online Privacy Protection Act and take measures to protect the personal information of Users.

2) Users can request confirmation of information leakage when their personal information is leaked. Also, all Users of our website can access their accounts and modify personal information at any time.

3) We shall not track website visitors. Also, we shall not use “Tracking Protection” signals.

4) Without User's consent, we will not collect personal identifiers through advertisements and will not provide the collected information to third parties.

14. Persons under the age of 13 residing outside of Korea

We will not knowingly collect any personal information from persons under the age of 13 who reside outside of the Republic of Korea. Persons under the age of 13 should not use our website or gaming platform at any time. If we have been notified that we have collected personal information from such persons, we will delete their information as soon as possible and in accordance with applicable laws and regulations.

In principle, our website and our Service are intended for adults. There is a minimum age requirement that must be met in order to sign up for an account to use our Service.

If we unknowingly collect personal information from Users under 13 years of age to provide our Service, the following additional processes shall be taken to protect the personal information of these persons:

1) Acquire agreement from the legal representative to collect personal information to directly provide information about our Service to the User

2) Notify parents about our Privacy Policy including content, purpose and sharing of information collected

3) Notify a legal representative about access to the User’s personal information, modification or removal of its personal information, temporary pause of its personal information process, and rights to withdraw the consent to provide its personal information provided in the past

4) We shall not collect information that is not necessary for participating in the online activity.

15. Users in the EU

Legal bases for processing your personal information

There are a number of different ways that we are lawfully able to process your personal information. We have described these below.

1) Where you give us your consent to process your personal information

We are allowed to use your personal information where you have specifically consented. In order for your consent to be valid:

■ It has to be given freely, without us putting you under any type of pressure;
■ You have to know what you are consenting to – so we'll make sure we give you enough information;
■ You should only be asked to consent to one thing at a time – we therefore avoid "bundling" consents together so that you don't know exactly what you're agreeing to; and
■ You need to take positive and affirmative action in giving us your consent – for example, we could provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

We seek your consent when you sign up to STOVE for the purposes of set forth in section 4 to section 7 hereinabove.  

Before giving your consent you should make sure that you read any accompanying information provided by us so that you understand exactly what you are consenting to.

You have the right to withdraw your consent at any time, and details can be found in the "Right to withdraw consent" section below.

2) Where processing your information is within our legitimate interests

We are allowed to use your personal information where it is in our interests to do so, and those interests aren't outweighed by any potential prejudice to you.

We believe that our use of your personal information is within a number of our legitimate interests, including but not limited to:

■  To handle customer complaints;
■ To verify User identity;
■ To ensure that our systems run smoothly;
■ Protection from improper use or unauthorized use of our Service; and
■ To market our services.

We don't think that any of the activities set out above will prejudice you in any way. However, you do have the right to object to us processing your personal information on this basis. We have set out details regarding how you can go about doing this in the "Your rights" section below.

3) Where processing your personal information is necessary for us to carry out our obligations under our contract with you

We are allowed to use your personal information when it is necessary to do so for the performance of our contract with you.

For example, we need to hold your email address in order to be able to send you email notification services where you have requested them.

4) Where processing is necessary for us to carry out our legal obligations

As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with, and we are allowed to use your personal information when we need to in order to comply with those other legal obligations.

For example, we are required to keep a register of people who own our securities and we will need to collect and hold certain personal information about you in order to satisfy that legal obligation.

 

Your rights

Applicable privacy laws in the EU grant you the following rights in relation to your personal information

To get in touch with us about any of these rights, please contact us at privacy_stove@smilegate.com.

We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

1) Right to object: this right enables you to object to us processing your personal information where we do so for one of the following reasons:

① because it is in our legitimate interests to do so (for further information, please see the section "Legal bases for processing your personal information" above);
② to enable us to perform a task in the public interest or exercise official authority;
③ to send you direct marketing materials; or
④ for scientific, historical, research, or statistical purposes.

2) Right to withdraw consent: Where we have obtained your consent to process your personal information for certain activities (for example, if you subscribe to email alerts), you may withdraw this consent at any time and we will cease to use your personal information for that purposes unless we consider that there is an alternative legal basis to justify our continued processing of your personal information for this purpose, in which case we will inform you of this condition.

3) Data Subject Access Requests: You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this as required by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost as permitted by law. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

4) Right to erasure: You have the right to request that we "erase" your personal information in certain circumstances. Normally, this right exists where:

① The information is no longer necessary;
② You have withdrawn your consent to us using your personal information, and there is no other valid reason for us to continue;
③ The personal information has been processed unlawfully;
④ It is necessary for the personal information to be erased in order for us to comply with our obligations under law; or
⑤ You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so.

When complying with a valid request for the erasure of information we will take all reasonably practicable steps to delete the relevant information.

If we have shared your personal information with third parties, we will notify them about the erasure unless this is impossible or involves disproportionate effort.

5) Right to restrict processing: You have the right to request that we restrict our processing of your personal information in certain circumstances. For example, if you dispute the accuracy of the personal information that we hold about you or you object to our processing of your personal information for our legitimate interests. If we have shared your personal information with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal information.

6) Right to rectification: You have the right to request that we rectify any inaccurate or incomplete personal information that we hold about you. If we have shared this personal information with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal information to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

7) Right of data portability: If you wish, you may have the right to transfer your personal information between service providers. In effect, this means that you are able to transfer the details we hold on you to another third party. To allow you to do so, we will provide you with your information in a commonly used machine-readable format so that you can transfer the information. Alternatively, we may directly transfer the information for you.

8) Right to complain: You also have the right to lodge a complaint with your local supervisory authority. Contact details for the various EU privacy supervisory authorities can be found here: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

16. Our Privacy Personnel

We have a personal information protection director to handle feedback and complaints relating to our use of personal information.

 

Chief Privacy Officer

Privacy Manager

Name

Dong Hee Kim

Young Kwon Kim

Department/Title

Dept. of Platform Operations / Head of Department

Dept. of Platform Operations / Team Leader

E-Mail

privacy_stove@smilegate.com

privacy_stove@smilegate.com

Users may contact the Personal Information Protection Director or Personal Information Manager listed above via message board or e-mail regarding any complaints or issues related to personal information they may face while using our Service. We will use our best endeavors to provide responsive and sufficient answers to Users.

17. Third Party Websites

We may provide Users with links to a third party’s website or data. Our Privacy Policy does not apply to such cases, and we have no control over external websites and their data. We will not be responsible for, or guarantee, the usefulness of service or data provided by these third parties. We do not have control over their policies and procedures so please refer to the privacy policies of these websites when accessing them through these links.