PRIVACY POLICY


Game Club SEA (the "Company") collects users' personal information to provide services related to Dark December through "www.darkdecember.net," in compliance with applicable laws.

By using the Company's services, users agree and give their consent to the collection, use, and storage of their personal information as described in this Privacy Policy. The Company is committed to protecting user's personal information and may update this Privacy Policy as needed to comply with laws or improve operational practices.

Article 1: Items of Personal Information Collected

1. During Member Registration, we collect the following personal information for login and user identification purposes.

   1. Mobile Game Services:

  • [Mandatory] Member Information: Email address, password, nickname, phone number, gender, country
  • [Mandatory] Account-linked information:

    • (1) Google: Public profile (name), Google-provided member number.

    (2) Meta: Public profile (name), Meta-provided member number.

    (3) Hive: Hive-provided member number.

    (4) Steam: Steam-provided member number.

   2. Game Portal Membership Registration:

  • [Mandatory] Member Information: Email address, password, nickname, phone number, gender, country.
  • [Optional] Member Information: Profile image.
  • [Mandatory] Identity Verification: (Information directly entered by the user for identity verification but not stored) Telecom provider, name, mobile phone number, date of birth, gender. (Information stored upon successful identity verification) Date of birth, linked information (CI/DI).

2. During the use of game and portal services, we may automatically collect and generate the following information to comply with relevant laws, protect accounts and items, prevent fraudulent users, and provide stable services.

   1. Mobile Game Services:

  • [Mandatory] During game installation and use: Download history, service usage records, connection logs (including IP address), records of improper use, device information (model name, MAC address, OS information and version, device language and country information, advertising identifier).
  • [Mandatory] When linking with social services: Member number.
  • The company does not collect or store social service-related information other than the member number.

   2. Game Portal Member Services:

  • [Mandatory] During the use of game portal services: MAC address, service usage records, connection logs (including IP address), records of improper use.

3. When using the customer center for smooth service use, we collect the following additional information:

   1. Inquiry Handling:

  • [Mandatory] Email address, nickname, device information (model name, MAC address, OS information and version).

4. For refund processing upon user request or service termination, we request the following personal information. The collected information may vary depending on the payment information, and separate consent is obtained if necessary.

   1. Game Service Refund Processing:

  • [Mandatory] (If account deposit is required): Name, date of birth, mobile phone number, payment account, bank name, bank account number, account holder, email address, copy of ID, copy of bankbook.

5. If the user wishes to participate in the company's events and marketing, the company may additionally collect and use the user's personal information. In this case, separate consent is obtained from the user.

   1. Game Portal Advertising Notifications:

  • [Optional] Email address, mobile phone number.

   2. Event Participation (e.g., pre-registration):

  • [Optional] Mobile phone number, email address, (in case of events using SNS) SNS account name.

   3. Delivery of Goods or Prizes:

  • [Optional] Name, mobile phone number, address, email address.

6. When using paid services, additional information may be requested to confirm order information and proceed with payment. The personal information collected and used may vary depending on the selected payment method.

   (1) Game Portal Store Payment:

   1. Receipt of Payment History:

  • [Mandatory] Email address (if no separate input, the login account email address is used).

   2. Payment Processing (Payment information required for paid transactions is collected and processed by the payment gateway):

  • [Mandatory] Payer ID, payer name, payer IP address, payer email address.
  • [Optional] (Varies by payment method): Card company, card number, card expiration date, card password, bank name, mobile phone number, date of birth, gender, telecom provider, simple payment (gift card) ID, simple payment (gift card) password.

Article 2: Methods of Collecting Personal Information

The Company may collect users' personal information through the following methods:

   1. Direct input by the user during the process of using the website or services.

   2. User responses during telephone consultations.

   3. Participation in events or activities conducted online/offline.

   4. Information received from partner companies.

   5. Collection through network communication information or connection history.

Article 3: Retention and Use Period of Personal Information

1. The collected personal information is retained and used while the user's membership is maintained. If the user's membership is terminated, or even if the membership is maintained, when the purpose of using the information is fully achieved, the information will be promptly destroyed. However, the Company retains user information for a specified period according to the 'retention period' provided to the user upon obtaining consent for the collection and use of personal information.

(1) Retention Purpose: To resolve consumer complaints and disputes upon withdrawal from game services. Retention Period: 30 days Retention Items: Connection records, connection date and time, connection location information, records of improper use, device information, download history, external platform ID.

(2) Retention Purpose: For marketing information and event-related notifications, and to select winners. Retention Period: 6 months (may vary by event; the period specified on the individual event page takes precedence). Retention Items: Name, mobile phone number, email address.

(3) Retention Purpose: To resolve consumer complaints and disputes upon withdrawal from community membership. Retention Period: 30 days Retention Items: Connection records, email address, password, nickname.

2. Notwithstanding the provisions of Paragraph 1, the Company retains information as required by relevant laws for the periods specified by those laws.

Article 4: Storage, Use, and Destruction of Personal Information

1. If it is necessary to retain information due to legal requirements, the Company may retain the user's personal information for a period exceeding the duration specified by relevant laws. In such cases, the retained information will only be used for the purpose of storage and will be destroyed after the "retention period" required by relevant laws, as specified under "grounds for retention."

2. Destruction Method:

  • Personal information stored in electronic file format is deleted using a technical method that makes the records unrecoverable.

Article 5: Provision of Personal Information to Third Parties

The Company uses the user's personal information only within the scope notified in the "Purpose of Collection and Use of Personal Information" in the Privacy Policy or within the scope specified in the Terms of Service, and does not use or provide it to third parties beyond that scope. However, in certain cases, the Company may provide personal information to third parties only with the user's consent or as permitted by applicable law. For example:

1. Recipient: Xsolla

2. Purpose of Use by the Recipient: Processing of paid transactions

3. Provided Personal Information: Credit card or payment information necessary for the transaction

4. Retention and Use Period: As required by applicable laws or regulations

Article 6: Procedures and Methods for Destroying Personal Information

1. The Company promptly destroys personal information after the purpose of collection and use has been achieved.

(1) Destruction Procedure:

  • The Company destroys personal information that has exceeded the retention period using a method that makes it unrecoverable.

(2) Destruction Method:

  • Personal information stored in electronic file format is deleted using technical measures that ensure it cannot be reconstructed or retrieved.
  • Personal information printed on paper is shredded using a shredder to prevent reconstruction.

Article 7: Entrustment of Personal Information Processing

1. The Company entrusts the processing of personal information as follows to perform services. The Company establishes and operates necessary measures to ensure the safe management of personal information in accordance with relevant laws when entrusting the processing of personal information.

(1) Entrusted Party: Com2us Hive Platform Entrusted Work: Login/authentication, billing, user management/device authentication, promotion execution, coupon issuance, customer center operation, billing, etc. Retention and Use Period: As required by relevant laws

Article 8: Installation, Operation, and Refusal of Automatic Personal Information Collection Devices

Cookies are small text files sent by the service operating server to the user's device, stored on the user's device. Cookie information is used solely for device identification purposes and does not identify individual users.

Purpose of Using Cookies:
The Company uses cookies to store and retrieve user information to provide personalized and customized services. Cookies are also used to analyze users' access frequency or usage time, understand user's preferences and interests, and use this information for targeted marketing and service improvement.

Refusal of Cookie Collection:
Users can restrict the storage of cookie information by setting options as follows. In the case of mobile apps, users can disable personalized ads using the following methods.

Android: Settings > Google Settings > Ads > Enable "Opt out of ads personalization"

iOS: Settings > Privacy > Advertising > Enable "Limit Ad Tracking"

Chrome: In the web browser, click the [⋮] icon > [Settings] > [Privacy and Security] > [Cookies and other site data]

Microsoft Edge: In the web browser, click the [•••] icon > [Settings] > [Privacy, search, and services]

Article 9: Technical/Administrative Measures for the Protection of Personal Information

The Company implements the following technical and administrative measures to ensure the security of personal information and to prevent its loss, theft, leakage, alteration, or damage.

1. Password Encryption:
User's passwords are stored and managed in an encrypted format. Therefore, even if a user forgets their password, it cannot be retrieved, and a new password is issued following the user's identity verification process.

2. Measures Against Hacking:
The Company employs various technical measures to prevent the leakage of user's personal information through abnormal network access, such as hacking and computer viruses. Continuous monitoring of network access is performed.

3. Minimization and Education of Handling Staff:
The Company's staff handling personal information is limited to designated personnel. A separate password is assigned to such personnel, which is regularly updated, and ongoing education is provided to ensure compliance with the Privacy Policy.

Article 10: Personal Information Protection Officer and Remedies for Infringement of Rights

1. Personal Information Management Officer and Department:
The Company has designated a Personal Information Protection Officer to take responsibility for the overall management of personal information processing and to handle complaints and damage relief for data subjects.

Position: Personal Information Protection Officer

Name: Jake Lee

Email: jake@needsgames.com

2. Remedies for Infringement of Rights:
You can apply for dispute resolution or consultation with the relevant institutions specified by law to seek remedies for damages caused by the infringement of personal information.
- Personal Information infringement Report Center (Contact 118): http://privacy.kisa.or.kr
- Supreme Prosecutor's Office Cyber Crime Investigation Unit (Contact 1301): http://www.spo.go.kr
- Cyber Terror Response Center (Contact 182): http://www.ecrm.police.go.kr

Article 11: Changes to the Privacy Policy

If there are any additions, deletions, or modifications to the content of this Privacy Policy, the Company will notify users through the service or website at least 7 days before the changes take effect.

Article 12: Notice of Privacy Policy

Effective Date of Privacy Policy: August 1, 2025