Effective Date: 2021.06.25

1. Introduction

KRAFTON, Inc. and/or its affiliates (“KRAFTON”, “we”, “our” or “us”) collect and process information about you (“you”, “user”, or “applicants”) when you visit, access, or use our official websites, including our careers page (collectively “Sites”). This Privacy Policy(“Policy”) describes how we collect and use personal information about you during and after your relationship with us. By visiting our Sites, or otherwise interacting with us through our Sites, you acknowledge the practices described in this Privacy Policy.

We will occasionally update this Privacy Policy. When we do, we will revise the effective date above. Your continued use of our website after such changes means you accept the Policy as revised. We encourage you to periodically review this Policy to stay informed about how we collect and process your personal information.

2. Information We Collect

What personal information we collect and process depends on how and why you interact with us.

  • A)Information you provide us: We collect information that you provide directly to us when you use our Sites. For example, you may provide us with your:
    • Name, email address, and any information you send us via our website, including information you provide through the “Contact Us” section or other methods (e.g., through Speak Up), for purposes of communicating with you;
    • Name, email address, name of the affiliated department, or phone number to answer your inquiries related to branding or other opportunities; and
    • Name, email address, phone number, date of birth, pictures, nationality, postal address, professional information or other information you provide to use in support of an application and/or the job application and recruitment process.
    • We must obtain consent before collecting or processing special categories of sensitive personal data (including veteran or disability information).
  • B)Information we collect automatically: We automatically collect certain information when you visit our Sites, some of which could be considered personal information (also known as “Session Data”). Session Data we automatically collect may vary, but generally includes:
    • Your device information (including OS version, model information, device ID, etc.);
    • Online identifiers (including IP address, MAC address, etc.);
    • What areas of the websites you accessed, browsed, searched for, or used; and
    • Time spent on our websites and related statistical information.

We do not use Session Data to personally identify you. We use it to administer, operate, and improve our Sites. The process by which we collect this information is through cookies related online technologies. See our “Cookies and Related Technologies” section below for more information.

3. How We Use Your Information

We use personal information collected through the Sites for the following purposes:

  • To manage our Sites, including inquiries and requests received from you through the Sites (e.g. through a Speak Up session, to respond to a partnership inquiry, etc.);
  • To assess potential job applicants and progress through the recruitment process;
  • Conduct analyses and develop reports of engagements and market trends of visitors to our Sites;
  • Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity;
  • Comply with and enforce legal requirements, agreements, and policies; and
  • Achieve purposes for which we provide specific notice at the time of collection.

In the majority of cases, our processing of your personal information is necessary to respond to you or process your request. We may also process your information to comply with a relevant legal obligation. For example, we may process your personal information to comply with legal obligations related to screening job applicants for employment, which may require the maintenance of certain records and for us to make mandatory disclosures to authorities. From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal by contacting us at the address provided in this Privacy Policy.

4. Sharing Your Information

We may share personal information with the following categories of parties and as otherwise described in this Privacy Policy or at the time of collection:

  • With our affiliates for the purposes described in this Policy, including to assess job applicants, progress the recruitment process, and respond to inquiries;
  • With our service providers who help us perform and deliver our services, including: website management, hosting, and analytics; communications; form processing; information technology and security; job application systems providers; recruitment providers; and auditing;
  • With the appropriate authorities if we believe disclosure is necessary to prevent physical, financial, or other harm, injury, or loss, including to protect against fraud or credit risk;
  • With legal, governmental, or judicial authorities as instructed or required by those authorities and applicable laws, or in relation to a legal activity, such as in response to a subpoena or investigation of suspected illicit or illegal activities, or where we believe in good faith that users may be engaged in illicit or illegal activities, or where we are bound by contract or law to enable a network partner to comply with applicable laws; and
  • With necessary third parties in connection with, or during negotiations for, an acquisition, merger, asset sale, or other similar business transfer that involves all or substantially all of our assets or functions where personal information is transferred or shared as part of the business assets.

5. Cookies and Related Technologies

As noted above, we use cookies and other technologies (like pixels, tags, and web beacons) when you interact with our Sites to improve their quality, store browsing preferences, and track usage trends, among other things. For these technologies to work, third parties collect and/or receive information from our Sites and elsewhere on the internet. These third parties typically collect information in the aggregate and in a way that does not personally identify you

Among other things, we use cookies from Google including Google Analytics. You can learn more about how those cookies work by visiting “How Google uses information from sites or apps that use our services,” located at https://policies.google.com/technologies/partner-sites. We also may use, from time to time, Facebook Advertising, Facebook Pixel Re-Marketing, and related technologies. These features allow us to measure the effectiveness of our Facebook ads. The data collected is usually in the aggregate such that we cannot see personal information of individual users but rather general demographic information that does not identify you. However, as this data is stored and processed by Facebook, Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy located at https://www.facebook.com/about/privacy/. You can opt-out of Facebook’s use of cookies and Facebook Pixel Re-Marketing through settings on your Facebook Account.

We do not control cookies in third party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. Please note, however, if you do not accept necessary cookies, some website features or services may not function properly. To find out more about cookies, visit http://www.allaboutcookies.org/.

Note, we do not process or respond to web browsers’ “do not track” signals. To find out more about “do not track,” please visit http://www.allaboutdnt.com.

6. International Data Transfers

We recruit and access our Sitess globally, and to provide our services we may transfer your data to other countries and other regions outside of where you are located, such as Korea, the E.U., the U.K., the U.S., Canada, India, and Singapore. However, we may transfer your data to other countries and/or regions to operate the Site and/or to meet legal requirement. By using our Sites and/or applying for a position, if applicable, you acknowledge that your personal information may be processed in a location outside of your own.

For residents of the European Economic Area (“EEA”), if we transfer your data outside of the EEA to a country that is not recognized by the European Commission as ensuring an adequate level of data protection, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing standard contractual clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for personal data). You may ask for a copy of such appropriate measures by contacting us as set out in this Privacy Policy. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.

7. Retaining and Deleting Personal Information

We generally retain your personal information for the duration of your relationship with us and will delete it after the purpose for the collection is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using technical measures in a way that cannot be reproduced.

8. Our Policy Concerning Children

We do not knowingly collect, use or share any personal information about children (age depending on the country where you reside) through our Sites. If you are a parent or guardian and you believe your child has provided us with personal information, you can contact us and request your child’s information to be deleted from our system.

9. Links and Third-Party Services

If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave the Site and go to the website you selected. Because we cannot control the activities of third parties, we do not have responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to our Sites, you should consult that site’s privacy policy before providing any personal information.

10. Protecting Your Information

While no one can guarantee your personal information is completely secure at all times, we use administrative, organizational, technical, and physical safeguards to protect the personal information we collect and process. Our security controls are designed to maintain data confidentiality and integrity, and give us appropriate access to your data. Among other things, we update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. We use professional third party service providers and data centers to provide our Sites, and enter into confidentiality agreements with them where appropriate. Those service providers and data centers implement industry-standard measures to protect the security of the personal information we collect, such as SSL (Secure Socket Layers), firewalls, digital certificates, and encryption.

11. Your Privacy Rights

Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information. To make a request concerning your rights or if you have any other question, please contact us by sending an email to the address specified in the “Contact Us” section. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

In certain countries, including in the EU, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

If you are a California resident, please refer to our Privacy Notice for California Residents for more information concerning your rights.

12. Contact Us

If you have any questions about this Privacy Policy, or your dealings with this Site, please contact us by sending an email at privacy@krafton.com. And you can also contact our Data Protection Officer by sending an email at DPO@pubg.com.