1. Scope of This Privacy Policy

This Privacy Policy applies only to services related to “Shadowverse: Worlds Beyond - Latin America” controlled by Cygames (the “Services”).

2. Personal Data Collected (Categories and Sources of Personal Data)

We may collect the following personal data:

• Your name, address, email address, and social media accounts, if you provide them to us
• Whether you are currently using the Services or you are still considering using the Services, and if you are currently using the Services, the version of the Services you are using
• Your Internet Protocol (IP) address, cookies, and other online identifiers
• Your behavioral data on the internet including browsing history and information on your interaction with a website
• Your date of birth and/or telephone number if necessary for us to provide the Services
• Information regarding the connection between you and other users in relation to invitations and referrals to the Services
• Device information
• Countries/areas where you live
• Log information
• Information about your accounts associated with the Services’ game platform
• Contents of your inquiries, including problems you experience, if you contact us to make inquiries
• Inferences drawn from personal data to create your profile reflecting a person’s preferences or behavior and the like
• Other personal data required to provide the Services (you will be notified separately of the category of data if required under applicable data protection regulations)

Personal data is collected directly from you, collected indirectly from service providers and platforms and other third parties, or inferred from collected data.

3. Cookies

We use cookies in the Services.

Cookies are small text files that websites send to your device for the purpose of keeping records. Cookies identify your device and, typically, your web browser. Some cookies are necessary to operate our website (e.g., establishing sessions), while other cookies provide enhanced functionality, gather analytical data to improve performance, enable us or our AdTech partners to deliver personalized advertisements by tracking you across the Internet, or enable sharing via social media.

You can choose whether to allow us or third parties (e.g., our analytics, AdTech, and social media partners) to set cookies which are not strictly necessary for the functioning of our website via the cookie banner and settings provided on our website.

Please be aware that when we talk about “cookies,” this term also includes other technologies (such as pixel tags and web beacons) which have the same purpose as the cookies described in this Privacy Policy.

First-party cookies are put on your device directly by the website you are visiting.

Third-party cookies are placed on your device, not by the website you are visiting, but by a third party such as an advertiser or a provider of analytics software.

If you would like to know the details of our use of cookies or change settings for the use of cookies, please refer to our .

You may also set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. If you do so, you may not be able to take advantage of the personalized features enjoyed by other users of the Services.

4. Use of Tracking and Similar Tools Provided by Third Parties

We engage in targeted advertising and use advertisers to serve advertisements on and off our Services. These third parties use cookies and similar technologies to collect or receive information from our Services and elsewhere on the Internet and use that information to provide you with targeted ads. You may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out via their official website (https://optout.networkadvertising.org/?c=1), or of companies participating in the Digital Advertising Alliance program by opting out here: https://optout.aboutads.info/?c=2&lang=EN. You can also use the Digital Advertising Alliance mobile app, available on the App Store, Google Play, and Amazon’s Appstore, to control interest-based advertising on apps on your mobile device. Mobile app guidance is available here: https://digitaladvertisingalliance.org/app.

Additionally, we use Google Analytics. Google Analytics is a web analytics service provided by Google LLC (“Google”) which collects anonymous statistical and analytical information about how our users use the Services. For example, Google gathers and aggregates data on page views and clicks within the Services. These analytics are not used to track your journey to other websites or to identify you. The information generated by the Google Analytics cookies about your use of the Services (including your IP address) will be transmitted to and stored by Google on servers in the United States.

You can find a more detailed account of Google’s privacy policy here:

https://policies.google.com/privacy?hl=en

Instructions on how to opt out of Google Analytics using a specific plug-in are available at the following link: https://tools.google.com/dlpage/gaoptout. Note that this opt-out is specific to Google activities.

We use Google Analytics for Firebase and Firebase Crashlytics. Google Analytics for Firebase is a web analytics service provided by Google which collects anonymous statistical and analytical information about how our users use the Services. Firebase Crashlytics is provided by Google and collects information about the device on which you are using the Service, information about crash conditions, and other information. The collection and use of device and other information is governed by the Firebase Policy, available at the following link: https://firebase.google.com/support/privacy.

We also use Adjust, an advertisement tracking tool for smartphone apps provided by Adjust GmbH. This tool makes it possible to measure and analyze the effectiveness of smartphone advertising. Adjust collects personal information as described below and aggregated information (information about groups or categories of persons, which does not identify and cannot reasonably be used to identify an individual person). Adjust uses IDFA, GPS, ADID, and log files to help the app analyze how users use the app. The information held in log files includes the user's IP address, internet service provider, and date/time stamp, as well as user activity. Furthermore, Adjust utilizes a variety of tracking methods to collect information.

You can find a more detailed account of Adjust’s privacy policy here: https://www.adjust.com/terms/privacy-policy.

We use Datadog, which is provided by Datadog, Inc., in conjunction with the use of the Services. Datadog is a service that acquires anonymized system log information issued in conjunction with the use of the Services and measures the your activity history, etc.

You can find a more detailed account of Datadog’s privacy policy here: https://www.datadoghq.com/legal/privacy/.

5. Your Choice Regarding Online Tracking

Our online services are not designed to respond to “Do Not Track” requests from browsers. However, you may communicate your privacy preference via the Global Privacy Control opt-out preference signal. To install Global Privacy Control, which is a device-specific browser or browser extension, please visit their official website (https://globalprivacycontrol.org/).

6. Use of Personal Data

We may process your personal data for the purposes described below:

• To deliver content such as games, video, and music; and provide related services
• To develop services; compile statistics, analysis, and questionnaires; and conduct other marketing activities intended to improve services
• To contact and communicate with you to respond to your inquiries and complaints
• To provide you with special offers, campaign information, updated information and other new services, newsletters, and any other information from Cygames or other third parties
• To complete a transaction or service requested by you
• To fulfill marketing or promotional purposes
• To allow you to share links to our content on social media
• To improve the Services
• To create and publish content that is the most relevant to you
• To notify you about a change to this Privacy Policy or the Terms of Service, if necessary
• To resolve disputes with you
• For other purposes of use as separately disclosed

Provision of your personal data is mandatory in some cases, such as for a statutory reason, contractual requirement, or a requirement necessary to enter into a contract. We may be unable to provide our service to you if you don’t provide such personal data.

7. Disclosure to Third Parties

We may share or disclose your personal data specified in Article 2 (Personal Data Collected (Categories and Sources of Personal Data)) to the extent necessary with or to third parties for the following purposes:

• To provide the Services to you, we may disclose your personal data to service providers. Service providers are agents or independent contractors which provide the Services on behalf of us (including those involved in the organization of esports competitions), help us develop and maintain the Services, and provide other administrative services to us. Such service providers include ExPlay, Inc., Keywords International Co., Ltd., and Kids Web Services, Ltd.
• In addition, to store and manage data on servers, we may use Amazon Web Services, Inc. (“AWS”), Zendesk, Inc., Akamai Technologies, Inc., Tencent Holdings, Ltd., and other cloud service providers to process your personal data. We may also disclose your personal data to service providers who provide services to evaluate the effects of advertisement. When engaging service providers, we enter into agreements for the protection of personal data with the delegated parties and request consent to the terms and agreements thereof so as to safely manage personal data.
• Data collection by social media providers and video distribution platforms: Buttons through which you can share our content on social media or video links to video distribution platforms may be embedded in our websites. In this case, the social media providers and video distribution platforms may obtain your personal data.
• To comply with laws and regulations, we may share personal data when necessary or in the good-faith belief that such action is necessary under the requirements of a law or regulation, a legally binding court order, or a governmental order from an investigative agency or competent regulatory authority that is issued with due process, to protect and defend our rights or property or both, or to act in urgent circumstances when it is necessary to protect the life, body, or property of a person, and the consent of the identified individual is difficult to obtain.
• We may share or disclose personal data with or to third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.

8. Security

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information that you transmit to us, and you understand that any information that you transfer to Cygames is transmitted at your own risk. Cygames specifies rules for the protection of personal data, and incorporates appropriate administrative, technical, organizational, and physical security measures that are required under applicable regulations. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of said firewalls and secure server software.

If we learn of any security systems breach, we may attempt to notify you electronically so that you can take the appropriate protective measures. By using the Services or providing personal data to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. We may post a notice on our Services if a security breach occurs. We may also send an email to you at the email address you have provided to us.

9. Rights of Data Subjects

We respect the rights you have under the personal data protection regulations applicable to you. You may demand the disclosure of, correction of, addition to, or deletion in the content of; stoppage or elimination of usage of; or stoppage of third-party provision of your personal data or disclosure of records for the provision of your personal data to third parties pursuant to the Act on the Protection of Personal Information of Japan. In addition to these rights, other rights may be granted to you under the applicable personal data protection regulations of other countries, as may be applicable. For example, in accordance with personal data protection regulations of an applicable country, you may be granted the following rights, and if the conditions prescribed by such personal data protection regulations are satisfied, we will comply with your exercise of such rights.

• Access to your personal data:
  The right to obtain confirmation from us on whether your personal data has been or is being processed, and if it has been or is being processed, the right to access the relevant personal data and specific related information
• Correction of your personal data:
  The right to modify incorrect personal data regarding you without unreasonable delay and the right to complete your personal data that is incomplete
• Deletion of your personal data:
  The right to delete personal data related to you without unreasonable delay
• Restriction on the processing of your personal data:
  The right to restrict the processing of your personal data
• Objecting to the processing of your personal data:
  The right to file an objection to the processing of your personal data if it affects your rights
• Withdrawal of consent:
  The right to withdraw your consent on which we rely to process your personal data (however, your withdrawal of consent does not affect the lawfulness of processing conducted based on your consent before its withdrawal)
• Data portability:
  The right to receive your personal data in a structured and generally machine-readable form, and the right to transfer the data to third parties without interference from us

If you wish to exercise any of the foregoing rights, please inquire with us using the contact information stated in Article 17 (Contacting Us). In order to confirm your identity, it may be necessary for us to ask for specific information from you. In addition, in order to streamline correspondences from us, we may contact you to ask for additional information in connection with your inquiry.

Further, you may directly file a complaint with the relevant supervisory agency in connection with our processing of your personal data.

10. Accounts Information

Access to your account and our Services is sometimes only possible through the use of an individual user ID and password. To protect the confidentiality of personal data, you must keep your password confidential and not disclose it to any other person. Please note that we will never ask you to disclose your password in an unsolicited phone call or email. CYGAMES IS NOT RESPONSIBLE FOR ACTIONS TAKEN REGARDING YOUR ACCOUNT WHILE A USER IS LOGGED IN USING YOUR USER ID AND PASSWORD.

11. Retention Period

We retain personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

12. International Transfer of Information

Personal data which you choose to provide to us will be stored in Japan. We may transfer (by any means including sending or allowing access) that information to countries or areas outside of the country or area where you live in accordance with applicable laws and regulations. At this moment, we transfer personal data to Japan and the United States. In addition, our service providers also use cloud servers provided by AWS, and your personal data may be processed in any of the regions or edge locations stated in the page below:

https://aws.amazon.com/about-aws/global-infrastructure/regions_az/

Such personal data may be processed by such parties for the term necessary to fulfill purposes specified in Article 7 (Disclosure to Third Parties).

13. Chat Rooms, Forums, and Other Public Posting Areas

Please note that any information you include in a message you post to any chat room, forum, or other public posting area is available to anyone with Internet access. If, for example, you do not want people to know your email address, do not include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS, AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS, AND OTHER PUBLIC POSTING AREAS.

14. Third-Party Services

This Privacy Policy applies solely to information collected on the Services. The Services may contain links to other web services. We are not responsible for the privacy practices or the contents of these other web services.

15. Changes to This Privacy Policy

We reserve the right to change this Privacy Policy from time to time. When we do, we will also revise the “last updated” date at the top of this Privacy Policy. For some changes to this Privacy Policy we may attempt to obtain your consent before implementing the change by placing a notice on the Services. The continued use of the Services following such notice will be viewed as consent to such changes unless otherwise specified.

16. Our Policy Regarding Children

If we learn that we have collected personal data from a child under the age of 13 without legal grounds, we will delete the information as quickly as possible. If you believe that we may have any information from or about a child under the age of 13 without legal grounds, please contact us by email at .

17. Contacting Us

If you have any questions about this Privacy Policy, our privacy practices, or regarding information on or the correction, blockage, or deletion of data, please contact us by email at .

Addendum for Residents of the European Economic Area and the UK

For residents of the European Economic Area and the UK, the following shall also apply.

PRIVACY POLICY ADDENDUM FOR LATAM
Shadowverse: Worlds Beyond – Latin America

1. Applications for this Addendum

1.1. This Privacy Policy Addendum for LATAM (“Privacy Addendum”) applies to the processing of personal data of users located in Latin America who access, install, use or interact with the game “Shadowverse: Worlds Beyond – Latin America” (“LATAM Version”), their regional pages, features, support, campaigns, purchases, virtual currency, digital items, or other related services (“Game” or “Services”). To avoid any doubts, this Addendum does not apply to the global version of “Shadowverse: Worlds Beyond”, previously released and operated separately by Cygames.

1.2. This Addendum complements the Privacy Policy made available by Cygames for the Game (“Privacy Policy”). In case of conflict between this Addendum and the Privacy Policy regarding users located in Latin America, this Addendum shall prevail only as far as necessary to fulfill the local applicable mandatory law.

1.3. This Addendum was created to reflect, in a regional and non-exhaustive manner, the privacy and data protection demands applicable in Latin America, including, when applicable, the Brazilian General Data Protection Law - Law #13.709/2018 (Lei Geral de Proteção de Dados, “LGPD”) and equivalent norms on personal data protection in the region’s other countries.

2. Who processes your personal data

2.1. Cygames is primarily responsible for the Game operations, for first degree support to users and for the processing of personal data related to the Services, except when indicated otherwise in specific notices.

2.2. Nuuvem and/or other local partners will be able to process personal data when acting in activities related to the regional page, localization, marketing, distribution, campaigns, reports, payments, antifraud, and services related to platforms under their control, including doubts, complaints, refunds, chargebacks, payment failures, purchase, or delivery errors or other activities authorized by Cygames in Latin America.

2.3. Depending on the activity performed, Nuuvem or other local partners will be able to act as service operators/providers, independent controllers, or joint controllers for the processing, as defined in the applicable contracts, in the instructions from Cygames and in the local law.

2.4. Whenever a purchase, access, payment, support, app store, third party platforms, social media, analytics tool, cloud provider, or payment gateway processes the user’s personal data, the privacy policies of these third parties will also be applicable.

3. Personal data that can be processed

3.1. Depending on the user’s interaction with the Game, its regional page, support, campaigns, and purchases, the following personal data might be processed:

• registration and identification data, such as name, email, country, language, date of birth, phone number, account identifiers, user ID, screen name, and data voluntarily offered by the user;
• access and device data, such as IP address, online identifiers, publicity identifiers, cookies, web beacons, pixel tags, logs, Session ID, operating system, browser, device model, technical settings, and usage information;
• data regarding the usage of the game and Services, such as activity in-Game, interactions, progress, purchases, virtual currency usage, digital items, events, preferences, behavior, usage history, messages, and content sent by the user;
• purchase and payment data, such as order number, value, currency, payment method, transaction status, chargebacks, reversals, refunds, data required for antifraud, and information processed by payment partners. Cygames and/or Nuuvem will be able to store full card data, which might be processed directly by gateways, acquirers, digital shops, or payment intermediaries;
• support and service data, such as the content in tickets, complaints, doubts, attachments, receipts, service history, records of communications, technical information, and data required to solve the request;
• marketing, campaigns and publicity data, such as communication preferences, consents, clicks, views, interactions with campaigns, participation in sales, and ad measurement data;
• inferences or derived information, such as preference profiles, segmentations, statistics, usage measurements, and behavior indicators, as allowed by the applicable law.

3.2. Additional data may be requested when necessary to comply with legal, tax, regulatory, anti-fraud, support, security, age-verification, child and adolescent protection requirements, or for the regular exercise of rights.

4. Purposes and legal basis of processing

4.1. Personal data might be processed for the following purposes:

• make the Game available, create and maintain accounts, allow access to Services, deliver content, record progress, operate events, process features, and make the user experience possible;
• process purchases, payments, virtual currency, digital items, refunds, chargebacks, antifraud, transaction confirmations, payment support, and financial records;
• respond to doubts, complaints, support requests, technical incidents, access issues, reports, and other interactions initiated by the user;
• guarantee the safety, integrity, fraud prevention, abuse prevention, moderation, account protection, auditing, investigation of forbidden behavior, and compliance with Global Terms and this Addendum;
• comply with legal, fiscal, accounting, consumer protection, regulatory, judicial, and administrative obligations or requests from the competent authorities;
• exercise rights in judicial, administrative, arbitration, or extrajudicial actions, including defense against complaints, chargebacks, frauds, and contract violations;
• send operational communications, security notices, changes in terms, relevant updates, information about purchases, support, events, and changes in the Game;
• conduct marketing activities, campaigns, sales, newsletters, recommendations, offers, and commercial communications, as allowed by the applicable law and the user’s preferences;
• conduct analytics, metrics, statistics, tests, improvements, research, product development, experience customization, and performance evaluation of campaigns;
• comply with obligations related to child and teenager protection, age verification, restrictions of features, and parental controls, when applicable.

4.2. The legal grounds may vary according to the user’s country and the purpose of processing. When applicable, processing may be based on contract execution, preliminary procedures, compliance with legal or regulatory obligation, regular exercise of rights, legitimate interests, credit protection/antifraud, protection of life or integrity, consent, best interest of children and teenagers, or other grounds permitted by local law.

4.3. Consent will be requested when demanded by law, especially for specific marketing activities, non-essential cookies, customized publicity, children’s or teenagers’ data processing, or other hypotheses on which the local law so demands. The user can revoke their consent through the available means, without loss of validity of any processing carried out prior to said revocation.

5. Cookies, analytics, publicity, and similar technologies

5.1. The regional pages, the Game and the Services will be able to use cookies, web beacons, pixel tags, SDKs, publicity identifiers, logs, and similar technologies to operate the service, maintain the session, remember preferences, improve security, measure performance, analyze usage, customize content, measure campaigns, and display publicity.

5.2. Strictly necessary cookies and technologies might be used for operation, security, authentication, fraud prevention, session maintenance, and delivery of our Services. Cookies and non-essential technologies, such as analytics, campaign measurements, customized publicity, and tracking by third parties, shall be used according to the applicable law and the preferences offered to the user.

5.3. The user can accept, decline, or adjust preferences regarding non-essential cookies through the available mechanisms on the website, in the app, via browser, on the operating system, in the app store, or through the opt-out tools specified in the Privacy Policy.

5.4. Both Cygames, Nuuvem or their partners can use tools for analytics, crash reports, adtech, campaign measurement, social media, and publicity providers. These third parties can process data according to their own policies when they act as independent controllers.

5.5. Behavior-based publicity, segmentation, profiling, or tracking involving children and teenagers must observe applicable legal restrictions in each country and might be limited, deactivated, or submitted to further control.

6. Personal data sharing

6.1. Personal data can be shared, to the extent required and permitted by applicable law, with:

• Cygames, its affiliates, subsidiaries, and companies of the same economic group;
• Nuuvem and other authorized local partners for regional activities, marketing, distribution, local page, payments, antifraud, reports, campaigns, and services related to the platforms under its control;
• hosting, cloud, infrastructure, security, analytics, crash reporting, customer service, CRM, moderation, anti-fraud, email, communication, and support providers;
• app stores, game platforms, payment platforms, gateways, acquirers, financial institutions, intermediaries, and billing partners;
• publishers, commercial partners, suppliers, and providers necessary to deliver the Game, purchases, events, campaigns, rewards, tournaments, sales, or specific features;
• public authorities, regulatory agencies, courts, consumer defense agencies, data protection authorities, fiscal authorities, or third parties, when necessary to comply with legal obligation, a valid order, investigation, the defense of rights, or protection against fraud and abuse;
• potential acquirers, successors or parties involved in corporate reorganization, merger, acquisition, sale of shares, or equivalent operations, in compliance with the applicable law;

6.2. Sharing will be limited to what is necessary for the purposes described in this Addendum, in the Privacy Policy, or in a specific notice. Cygames and its partners will adopt reasonable contractual, technical, and organizational measures to protect shared personal data.

6.3. The user database shall not be sold, rented or transferred to third parties for purposes that are incompatible with this Addendum, with the Privacy Policy, or with the applicable law.

7. International data transfer

7.1. Since the Game is operated globally, the personal data of users located in Latin America can be stored, accessed, or processed outside the user’s country of residence, including Japan, the United States, and other countries where Cygames, its affiliates, Nuuvem, cloud providers, platforms, gateways, analytics tools, suppliers, or partners are located.

7.2. International transfers will be carried out according to mechanisms allowed by applicable local law, which may include contracts, specific data protection clauses, consent when required, contract compliance, regular exercise of rights, global services provisions, or other legally recognized hypotheses.

7.3. Whenever it is demanded by applicable law, Cygames and/or their partners shall adopt reasonable measures to ensure the adequate levels of protection to personal data that is transferred internationally.

8. Children and teenagers

8.1. The processing of children’s and teenagers’ personal data is subject to the applicable local law and will be conducted in a manner compatible with their best interests, with appropriate transparency and reasonable protection measures.

8.2. Depending on the country, user’s age, functionality, and type of processed data, consent, authorization, assistance, or awareness from parents or legal guardians may be required.

8.3. Cygames, Nuuvem, and authorized partners may adopt age verification measures, restrict purchases, limit customized publicity, disable social features, block certain content, suspend transactions, request additional confirmation, or remove/anonymize data, when necessary, to comply with the applicable law.

8.4. If parents or legal guardians believe that data from a child or teenager has been processed without appropriate legal grounds or wish to exercise rights in the name of the minor, they can contact through the channels indicated in the Privacy Policy, in this Addendum, or in the regional page.

9. Holders’ rights

9.1. According to the applicable law in the user’s country, the holder of such personal data may have the right to:

• confirm the existence of any processing of their personal data;
• access their personal data;
• correct data that is incomplete, inaccurate or out of date;
• request anonymization, blocking, elimination, or suppression of data that is unnecessary, excessive, or processed in noncompliance with the law;
• request portability, when applicable;
• obtain information about the sharing of personal data;
• revoke consent when processing is based on consent;
• oppose to some processing, when applicable;
• request revision of automated decisions, when provided for by law;
• file a complaint with the competent data protection or consumer protection authority.

9.2. To exercise their rights, the user must refer to the contact channels indicated in the Privacy Policy, on the regional page, or in this Addendum. Additional information may be required to confirm the applicant's identity, protect the account, prevent fraud, and ensure that data is provided only to the data subject or an authorized representative.

9.3. Certain requests may not be completely fulfilled when retaining the data is necessary for compliance with a legal or regulatory obligation, performance of a contract, fraud prevention, security, the regular exercise of rights, the protection of third parties, or any other ground permitted by applicable law.

10. Data retention and removal

10.1. Personal data will be retained for the period necessary to fulfill the purposes described in this Addendum and in the Privacy Policy, including Game operation, support, purchases, security, anti-fraud, compliance with legal, tax, accounting, regulatory, consumer protection, and judicial obligations, and the regular exercise of rights.

10.2. When the data is no longer necessary, it will be removed, anonymized or kept in a limited way, as allowed by the applicable law.

10.3. Even after a deletion request, account closure, or termination of the use of the Services, certain data may be retained to the extent necessary for compliance with legal obligations, transaction processing, fraud prevention, chargebacks, auditing, the defense of rights, security, abuse investigation, or protection of third parties.

11. Security and incidents

11.1. Cygames, Nuuvem, and/or its authorized partners will adopt technical, administrative, and organizational reasonable measures to protect the personal data against unauthorized access, loss, misuse, alteration, disclosure, or wrongful destruction.

11.2. Despite the security measures in place, no system is completely risk-free. Users should also protect their credentials, use strong passwords, not share their account, keep their devices secure, and report any suspicion of wrongful access.

11.3. In case of a security incident that may create a significant risk or damage to users, Cygames, Nuuvem, or the applicable controller will take the measures required by local law, including, where necessary, notifying affected users and/or competent authorities.

12. Contact channels

12.1. Questions, requests, and inquiries related to privacy and data protection may be directed to the channels indicated in the Cygames Privacy Policy, on the Game's regional page, or through any other channel communicated to the user.

12.2. If Nuuvem processes personal data in connection with payments, purchases, refunds, chargebacks, payment failures, purchase or delivery errors, the regional page, or other activities carried out on platforms under its control, it may provide its own channel for requests related to these activities, without prejudice to the main channel designated by Cygames for issues related to the Game.

13. Changes in this Addendum

13.1. This Addendum may be updated periodically to reflect changes in the Game, regional operations, tools used, partners, data processing practices, applicable law, or guidance issued by competent authorities.

13.2. Material changes shall be communicated through reasonable methods, such as an update to the page, an in-Game notice, via email, the support center, or another appropriate channel, when required by applicable law.