Contents

I. What does this Privacy Policy cover?

II. What types of information does NCSOFT collect?

III. From what sources does NCSOFT collect Personal Information?

IV. What third parties collect Personal Information on behalf of NCSOFT?

V. For what purposes does NCSOFT collect Personal Information?

VI. With whom does NCSOFT share Personal Information?

VII. How does NCSOFT treat Personal Information transferred out of the EU?

VIII. How is my Personal Information protected?

IX. What rights do you have to your Personal Information?

X. How does NCSOFT use cookies and other identifiers?

XI. Are there any special categories related to Personal Information?

XII. How will NCSOFT notify users of changes to this Privacy Policy?

XIII. How can someone contact NCSOFT?

LAST UPDATED: 01/06/2020

PRIVACY POLICY

We at NCSOFT work hard to provide high quality online and mobile gaming experiences. With so many individuals logging into and connecting through our games, we understand the importance of your privacy. Maintaining your privacy and the trust of our users is important to us. NCSOFT may store, process, and, under certain circumstances, share your information as described in this Privacy Policy.

Throughout this Privacy Policy we refer to “Services,” which means our websites, games, surveys, promotions, contests, purchases, community support, and related activities. Also, when we use the terms "NCSOFT", “we”, “us” or their derivatives, we are referring to, collectively, NC Interactive, LLC, ArenaNet, LLC, and NCSOFT Europe, Ltd.

I. What does this Privacy Policy cover?

This Privacy Policy explains how we collect, use, protect, and store your Personal Information (defined below) and how we comply with applicable data protection laws. It only applies to NCSOFT’s websites, services, products and offerings. It does not apply to other non-NCSOFT service providers and websites, including those to which we may link. Those websites, services or games will have their own privacy policies, which you will want to review and understand.

This Privacy Policy describes our processing and practices related to your Personal Information. By using our Services, you are confirming that you understand English (or, in some cases French, German, or Spanish) well enough to understand this Policy. Should you have questions about this Policy, please contact us as described below, so we can clarify and address your questions.

II. What types of information does NCSOFT collect?

We may collect different types of information from you depending on how you use our Services, including Personal Information. “Personal Information” means information that relates to an identified or identifiable natural person.

Examples of Personal Information we may collect include the following categories of information:

§ Full name

§ Date of birth

§ Email address(es)

§ Mailing address

§ Language and other information about location

§ Social security number

§ Age

§ Phone number

§ Social media account (e.g., Twitter handle, Facebook account, etc.) identifiers created by third-party platforms used to download and/or access our games (e.g., a “SteamID”, which is a unique identifier used to identify a Steam account)

§ Billing data

§ Account identification number

§ Purchase and account transactions history

§ In-game ID, character name, gameplay history and other gaming activity information

§ Game file version

§ Device ID, MAC address, and IP address

§ Computer operating system and system specifications

§ Mobile OS Version and certain information concerning devices you use to access the Services

§ GeoIP information

§ Internet browser provider and type

§ Your “click path” and pages visited on our websites

§ The advertisement, website or link that brought you to one of our websites and any site visited immediately after leaving one of our websites

§ Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

We may also collect information that does not generally identify you but may become associated with your account. We reserve the right to use information that does not generally identify you in connection with any lawful purpose.

III. From what sources does NCSOFT collect Personal Information?

A. From you

We may collect your Personal Information when you provide it to us directly through the Services you use, for example when you:

1. Register for an account, contest or giveaway

2. Submit additional information on the account page

3. Order products

4. Submit a job application

5. Send email messages, submit forms, or contact us

6. Respond to surveys or customer questionnaires

7. Report a problem with the Services

8. Play games

B. From Third Parties

We also may receive Personal Information from or through certain third-party services that help us provide the Services and/or facilitate your access to the Services, including, by way of example, third-party platforms that you may use to log in and access our Services (e.g., Facebook, Google, Game Center) and the third-party services described in Section IV of this Privacy Policy (e.g., payment processors and advertising partners).

We abide by this Privacy Policy when we use Personal Information provided to us by third parties. However, we do not control the information that these third parties collect or how they use that information. You should review these third parties' privacy policies for more information about how they collect, use, and share information they obtain and use, including the information they may disclose to us if you use their service credentials to log in to our Services.

What third parties collect Personal Information on behalf of NCSOFT?

A. Payment Processors

For security reasons and to better protect your privacy, we do not directly collect or store your payment information. Should you choose to make financial transactions through our Services, we use third-party payment processors who collect payment information on our behalf to process your transactions. Specifically, payment, billing and credit card verification services may need to collect certain Personal Information in order to access your payment methods and process your transactions. If you choose not to provide Personal Information for payment processing needs, they will not be able to complete your requested transaction(s) on our behalf.

B. Advertising Partners

We may receive Personal Information about you from third-party advertising partners that manage advertising campaigns on our behalf. For example, if you click on an advertisement that directs you to one of our Services (such as a banner advertisement located on a third-party website), we may receive information concerning the advertisement, website or link that brought you to one of our websites and the applicable ad campaign.

C. Customer Support Partners

We may use third-party customer service platforms that help us provide support to our users by offering them a means by which they may contact us with inquiries about our Services. Some of these customer service platforms may provide us with certain Personal Information (e.g., email address) of users that reach out for support.

D. Fraud Protection and Authentication Service Providers

Fraud protection and authentication service providers may collect Personal Information on our behalf concerning the devices of our users. This information may be collected when users log in to one of our websites. This information may be used to help us maintain the integrity of our Services.

E. GeoIP Location Service Providers

GeoIP location service providers may collect information for us about the location of our users. This may be collected when a user logs in to one of our Services. This information may be used to help keep the Services more secure and create a more customized experience for our users.

F. Recruitment Service Providers

We may work with third parties to facilitate our processing and review of job applications. In certain cases, users may submit job applications and other Personal Information through cloud-based facilities made available by these recruitment service providers. If you make use of such a facility, the relevant recruitment service provider will provide us with your Personal Information to help us review your job application.

For what purposes does NCSOFT collect Personal Information?

A. To Provide the Services

We may need certain Personal Information to provide our Services to you or to complete a transaction. We use Personal Information for the purposes for which you provide it and the Services you use and as otherwise may be permitted under this Privacy Policy and applicable law. For example:

1. We may use Personal Information such as phone number, address, and social media profile information to offer, administer and improve our Services, including using your Personal Information to provide customer support, to market our products and services, to provide a game, event or contest, or to understand how users interact with our websites and our other products, so we can work to optimize users’ experiences with them.

2. We use billing data, including payment card or bank information for purchases you make and customer support requests about refunds and chargeback requests.

3. We may collect, use, and store your Personal Information, including your email address and information about the device through which you access the Services, to set up your account as part of the registration process.

4. We may collect, use, and store your Personal Information to fulfill your requests and maintain records of our provision of the Services to you. If you attempt to initiate a transaction with us or make a request of us, but do not provide the Personal Information we need, we may not be able to process the transaction or provide the requested Service.

5. We may use your Personal Information and/or aggregate or anonymized information to help us target advertising on social media or third-party websites.

6. We may use Personal Information that you submit to us when you apply for a job (e.g., name, address, and email) and for recruitment-related activities, such as setting up and conducting interviews for applicants and evaluating and assessing the results.

7. When you communicate through a Service, even privately, we process, store, and may monitor those communications to detect cheating, fraud, illegal activity, or other activities that may violate one of our User Agreements.

B. Lawful Basis

We only collect, use, or store your Personal Information if:

1. You voluntarily provide it to us with your specific and informed consent (for example, when signing up for our newsletters or in connection with the creation of a profile for marketing campaigns, including on social media or through email).

2. It is necessary to provide you a Service that you have requested (for example, providing you access to our games).

3. We have a legitimate business interest that is not outweighed by your privacy rights (for example, to maintain records of sales through our online store, to enforce fair and consistent rules for all players, or to detect cheating, fraud, illegal activity, or other activities that may violate one of our User Agreements).

4. It is necessary to protect your vital interests or the vital interests of others (e.g., we may collect or share Personal Information where necessary to resolve an urgent medical situation or protect the health or safety of one of our players or someone else).

With whom does NCSOFT share Personal Information?

A. Third-Party Service Providers

We do not share Personal Information with third parties for their direct marketing purposes; however, we may share your Personal Information with third-party service providers that are subject to contractual and legal limitations on how they may use Personal Information they process. These limitations generally prohibit service providers from using Personal Information for any purpose other than the purpose for which it was provided or collected. When we share Personal Information with service providers, we do so to provide you with access to our Services and to administer, improve, present, and market our Services and business. The categories of third-party service providers that we may disclose Personal Information to include the following:

Fraud detection and management services, authentication services, and vendors that assist us with managing other risks associated with our business
Customer support and localization (i.e., translation) vendors
Marketing and advertising platforms and marketing companies, including service providers that help us manage contests, sweepstakes, surveys, and similar promotional events
Cloud-based recruitment services providers that assist us with processing job applications and other related recruitment activities
Social media websites, server providers, and email providers
Moderation and user experience providers
Fulfillment houses
Consultants, attorneys and similar service providers that are obligated to keep Personal Information secure and confidential and use it only for the purposes for which we disclose it to them

B. Other Parties

We may also disclose your Personal Information in the following circumstances:

We may disclose your Personal Information to law enforcement or other appropriate third parties in connection with criminal, fraud, infringement, other investigations related to suspected illegal activities, to protect the health and safety of our players, personnel or third parties, as may be required or allowed by applicable law, or to protect the legitimate legal and business interests of NCSOFT, our personnel and customers.
We may disclose your Personal Information where necessary to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
We may disclose your Personal Information to our subsidiaries and affiliates. For example, this may occur where an affiliate’s personnel provide support in connection with offering one of the Services or where there is a reallocation of organizational resources among our affiliated entities.

C. For Your Protection

We take reasonable precautions before sharing your Personal Information with third parties and require that third parties with whom we may share Personal Information provide adequate protections. Except as described in this Privacy Policy, we will not share any of your Personal Information to any third party without your express approval. If third parties collect, use, or store your Personal Information on our behalf, we require that they do so in accordance with applicable law, reasonably limit their retention and use of your Personal Information, and that they use appropriate security measures to protect your Personal Information.

How does NCSOFT treat Personal Information transferred out of the EU?

A. Place of Business

We may store or process your Personal Information outside of the country where we collect it or which you reside. NCSOFT has its primary places of business in the United States of America and United Kingdom. You should understand that we may transfer some or all of your Personal Information to the United States of America to carry out certain operational and processing needs as described in this Policy.

B. Transfer Mechanisms

When transferring Personal Information out of the EU, we implement technical, organizational, and physical safeguards to protect your Personal Information. We use European Commission approved standard contractual clauses, and Privacy Shield certification and implement related measures required by applicable law.

Please contact us if you have questions related to the relevant transfer mechanism for your Personal Information.

C. Privacy Shield

NCSOFT complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and Switzerland to the United States. NCSOFT has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. NCSOFT is responsible for the processing of the Personal Information we receive and subsequently transfer to a third party acting as an agent on our behalf, and we remain liable if a third party acting on our behalf uses your Personal Information in a way that is inconsistent with our obligations under Privacy Shield, unless we can prove that we are not responsible for the event giving rise to the damage. In compliance with the Privacy Shield Principles, NCSOFT commits to resolve complaints about our collection or use of your Personal Information. European Union or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact NCSOFT using the information found at the end of this Privacy Policy. NCSOFT commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by the panel and Commissioner about Personal Information transferred from the EU or Switzerland. The Federal Trade Commission has jurisdiction over NCSOFT’s compliance with the Privacy Shield. You may have the right, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. See https://www.privacyshield.gov/article?id=ANNEX-I-introduction for more information.

How is my Personal Information protected?

A. Our Retention, Purpose Limitation, and Security Policies

We protect your Personal Information through a combination of collection, security, and retention policies.

1. Limited Retention. We only keep your Personal Information for as long as we need it for business and operational needs or to comply with any statutory, regulatory, or legal obligations.

2. Purpose limitation. We will use your Personal Information only for the Services you choose to access and for the purposes for which you choose to share it. We will respect your requests to start or stop processing your Personal Information for marketing purposes, as well as the types of marketing messages you may wish to receive.

3. Security Measures. We use appropriate measures to keep the Personal Information we collect and use in a secure environment, and we have implemented technical, administrative, and physical security measures designed to protect Personal Information from unauthorized access, disclosure, use, and modification. As part of our privacy compliance processes we review these security procedures on an ongoing basis to consider new technology and methods as necessary. However, please understand that our implementation of security measures as described in this Privacy Policy does not guarantee the security of your Personal Information.

B. Your Practices and Activities

Your practices and activities are likewise very important in the protection of your own Personal Information. You can take certain steps to help protect your Personal Information, such as being mindful of what you post in public places.

1. Do not use your real name when selecting a username. Your username will be available to the internet's general public while you participate in some Services, like forums, chat rooms, or message boards, so you should exercise your own discretion when using these Services.

2. Do not post your real name in public-facing areas of the Services, such as forums, chat rooms, or message boards, and do not share anything private about yourself on such public platforms, including your phone number or address. Use usernames instead of real names at all times.

3. Many types of communications, especially those on public forums or social media, are generally available to the public or large groups of unknown users. Remember that we have no control over what third parties do with the content of such communications and no responsibility or obligation regarding third parties’ collection or use of communications you share. To the extent that you are create a public profile that may be available to others on our Services, you are solely responsible for its content at all times.

What rights do you have to your Personal Information?

A. Right to Access, Correct, Delete, or Restrict Processing

Subject to any limitations under applicable law, you have the right to request access to your Personal Information and exercise a number of rights:

You have the right to correct or update certain types of Personal Information. In many cases, you can review or update the Personal Information in your account by accessing your account online.
You have the right to request deletion of your account and related Personal Information. If you choose to have your Personal Information removed from our active databases, we will carry out your request within 30 days of account verification and will only retain minimal information to document your request and the actions we took to carry out your request.
You have the right to restrict certain processing of your Personal Information, and the right to object to some types of processing of your Personal Information.
You have the right to object to your Personal Information being used for marketing or advertising purposes.

We will comply with your rights requests in accordance with, and subject to, applicable law. Please note that we are legally prohibited from carrying out requested actions in some instances, including (1) when we are unable to confirm your identity; (2) where the request is considered excessive, and (3) where doing so would adversely affect the rights or freedoms of other individuals.

B. We are here to help

Please contact us at ncprivacy@ncsoft.com or using the contact information provided in Section XIII of this Privacy Policy if you would like to exercise any of the rights described above or if you have questions regarding your rights.

You also have the right to contact our data protection officer (DPO) if you are unsatisfied with how your request is being handled. To get in touch with him or her for any information concerning our processing of Personal Information, please contact: DPO@ncsoft.com.

C. Right to Lodge a Complaint

You have the right to lodge a complaint regarding our collection, processing, or storage of your Personal Information with a data protection supervisory authority in the country where you live or work.

How does NCSOFT use cookies and other identifiers?

A. Cookies and Tracking Pixels

When you visit one of our websites, we may ask your browser to store a “cookie”, which is a small text file, on your device to remember information about you, such as your language preference or login information. We and our third-party providers use cookies to assign a unique number that automatically identifies your computer when you visit our websites. Some cookies remain on your computer until you delete them; others, like session ID cookies, expire when you close your browser. We and our third-party providers also use other identifiers (such as Clear GIFs, pixels, web beacons) to track the pages visited on our websites or the emails and other communication we send. Such tracking identifiers are tiny graphics that are embedded invisibly on web pages or in HTML-based emails.

B. Purposes

We use cookies and other tracking technologies for the following purposes:

1. To assist you in navigating our websites or to display certain types of content;

2. To assist you in registration for our events, to log in to certain features or to provide us your feedback;

3. Analyzing your use of our Services, functionality and use of our pages and links, collecting aggregated user data, and traffic sources; and

4. Tracking our promotional and marketing efforts.

C. Third Party Cookies

Some cookies on our websites come from third-party advertisers or analytics providers. These cookies improve your experience by helping us better tailor our websites to our audience. We work with third-party advertising and analytics providers to help collect information about website visitors and account holders and their usage of our Services. Those third-party providers may use cookies and tracking identifiers to collect, and may otherwise have access to, information about users of our Services, including Personal Information. For example, third-party providers may collect or otherwise have access to usage information (e.g., information about the pages where users enter and exit our websites, what pages they view on our websites, etc.), device information, online identifiers of users, and demographic and interest-level information.

D. Google Analytics

We use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, US. On a de-identified basis, Google analyzes your use of our websites on our behalf. The information collected by Google in connection with your use of our websites is transmitted to a server of Google in the US, where it is stored and analyzed. For information about how Google Analytics collects and processes data, please see the following link: https://www.google.com/policies/privacy/partners/. Google’s collection and use of information is subject to Google’s Privacy Policy. If you would like to opt out of Google Analytics tracking, please visit one of the following links:

1. Google Ads Settings (http://www.google.com/settings/ads), or

2. the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout/)

E. Google Campaign Manager

Our websites may use Campaign Manager (formerly Doubleclick) by Google. Campaign Manager serves cookies to help us display relevant advertisements to our users, understand the performance of our ad campaigns, and prevent users from seeing the same ad multiple times. These cookies may collect information about your actions and otherwise track your behavior on third-party websites, including conversions related to ad requests. If you would like to opt out of Google Campaign Manager tracking, you can install the appropriate plugin for your browser (if you use Chrome, Firefox or Internet Explorer) by following this link and/or adjust your browser settings to not accept cookies. Note that, by installing the plugin or changing your browser settings, you may still receive ads, but they may not be targeted.

F. Unity Ads

In some of our or our affiliates’ Services, we may use Unity Ads, an advertising service offered by Unity Technologies, 30 3rd Street, San Francisco, CA 94103 and Unity Technologies Finland OY, Kaivokatu 8 B, 00100 Helsinki, Finland. We do not send Unity Ads your Personal Information. Rather, Unity Ads collects Personal Information directly from your device, and uses this Personal Information to provide you targeted advertising. You can view their privacy policy, which includes instructions on how to restrict the collection of Personal Information, by visiting their website (https://unity3d.com/legal/privacy-policy).

G. Sizmek

Sizmek helps us tailor our advertising to our users and create a more personalized experience for them. Additional information about Sizmek may be found at www.sizmek.com. Details about Sizmek’s privacy policy and cookies policy is available at https://www.sizmek.com/privacy-policy/ and https://www.sizmek.com/cookie-policy/ respectively. For information on how to disable Sizmek tracking and/or to opt out of Sizmek, you can click on the opt-out link at https://www.sizmek.com/privacy-policy/.

H. Browser Settings; Choices about Cookies

You may set your browser setting to attempt to reject the cookies and tracking identifiers, and you may still use our websites. However, you may be limited in some areas of our websites, or you may have to enter passwords or identifying information more than once.

As discussed above, we may use cookies and other tracking identifiers to collect information about your online activities over time and across third-party websites or other online services. Click here for information on how you may be able to opt out of tracking and mechanisms that may enable consumers to exercise choice about tracking.

Are there any special categories related to Personal Information?

A. Minors

1. Our Services are not designed for children, and we do not intentionally collect, maintain, or disclose any Personal Information from children. A “child” is usually considered to be under the age of 13 under applicable law; however, depending on where you live, the age which a person receives special protections for their data may be higher.

2. If you are a parent or guardian of a child who has submitted Personal Information, you can request removal by sending us an email at ncprivacy@ncsoft.com. If you do so, please provide the same username and email address that your child submitted. If your child has used your credit card on our Services without your permission, please contact us immediately at ncprivacy@ncsoft.com.

B. California

1. We provide registered users the ability to post information on our Services. If you are a California resident who is under 18 and a registered user and you are unable to remove content or information you posted in a public area following the instructions provided, you may request removal by contacting us. When requesting removal you must be specific about the information or content you want to remove and provide the URL for each place it is located. We are not required to remove any content or information that: (a) we, or a third party, are legally required to maintain; (b) was not posted by you; (c) is anonymized so that you are not identified; (d) is not based on a request that follows our instructions for removing or requesting removal; or (e) you received compensation or other consideration for providing the content or information.

2. California Civil Code Section 1798.83 permits California residents to request information from us concerning any disclosures of Personal Information we may have made in the prior calendar year to third parties for direct marketing purposes. If you are a California resident and you wish to request information about our compliance with this law or our privacy practices, please contact us at ncprivacy@ncsoft.com.

3. If you are a California resident, the California Consumer Privacy Act of 2018 (“CCPA”) requires us to provide you with additional information concerning our use of your Personal Information:

I. In the preceding 12 months, NCSOFT has not sold Personal Information. NCSOFT only shares Personal Information with service providers.

II. In the preceding 12 months, NCSOFT has disclosed the following categories of Personal Information for a business purpose:

§ Identifiers

§ Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

§ Commercial information

§ Internet or other similar network activity

§ Geolocation data

§ Protected classification characteristics under California or federal law

4. If you are a California resident, you have the right to request that NCSOFT disclose certain information to you about how we have collected and used your Personal Information during the past 12 months. Once we receive and confirm a verifiable consumer request from you, we will disclose the following information to you:

The categories of Personal Information we collected about you during the past 12 months.
The categories of sources from which we collected Personal Information about you during the past 12 months.
The categories of third parties with whom we share that Personal Information.
Our business or commercial purpose for collecting and sharing the applicable Personal Information.
The specific pieces of Personal Information we collected about you during the past 12 months (sometimes referred to as a “data portability request”).
To the extent we disclosed your Personal Information for a business purpose, a description of such disclosures that identifies the categories of Personal Information obtained by each category of recipient.

5. If you are a California resident, you have the right to request that NCSOFT delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception under the CCPA applies, including, for example, where the relevant Personal Information is needed to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

6. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing your request to ncprivacy@ncsoft.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of a person about whom we collected Personal Information; and
Describe your request with enough detail to allow us to properly understand, evaluate, and respond to the request.

To be clear – any disclosures we provide in response to a verifiable consumer request will only cover the 12-month period preceding the verifiable consumer request’s receipt.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you or the person on whose behalf you are making the request. We will only use Personal Information provided in a consumer request to verify the requestor's identity or authority to make the request. If we cannot comply with a request (including where we cannot verify it), we will explain the reasons we cannot comply with a request.

We will take steps to respond to a verifiable consumer request within 45 days after we receive it. If we require more time to respond, we will inform you of the reason for the delay and extension period in writing. We will deliver our written response by mail or via email, at your option.

For data portability requests, we will choose a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

7. We will not discriminate against you for exercising any of your rights described in this Section XI(B). Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, to the extent permitted by CCPA, we may offer you certain financial incentives that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your Personal Information and contain written terms that describe the program’s material aspects. Participation in a financial incentive program, if we offer one, requires you to opt-in in advance, and you may opt out at any time.

How will NCSOFT notify users of changes to this Privacy Policy?

NCSOFT reserves the right to change this Privacy Policy at any time. When we do, we take steps to notify registered users via email of the existence of a new Privacy Policy. We also take additional steps such as placing a clear notice on the Services, posting the new Privacy Policy on our websites, or other notification methods that may be appropriate based on the nature of the updates. All changes to the Privacy Policy will be effective when posted, and your continued use of any of the Services after the posting will be subject to the updated Privacy Policy.

How can someone contact NCSOFT?

For NCSOFT our mailing address is:

3180 139th Avenue, Suite 100

Bellevue, WA 98005, USA

Our customer service email address is support@ncsoft.com.

Our privacy email is ncprivacy@ncsoft.com.

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