Privacy Policy of König des Meeres

Effective Date:  February 14th, 2022

Welcome to The King of Ocean! The game is published and operated by Watchwell Pte. Ltd. (“Watchwell”). We are controller of your personal data and we are committed to protecting and respective your privacy. This privacy policy applies to the King of Ocean game, related store, site and services (collectively, the “Services”). 

The basis of processing your personal data for the various purposes is set out under the respective portions. 

If you do not agree to this privacy policy, please cease using our website and/or Services immediately. In the event that you have disclosed your personal data to us, please exercise your right to withdraw your consent as detailed herein.

This Privacy Policy describes:

• How you can contact us;
• The ways we collect personal data about you;
• Why we do so;
• How we use your personal data;
• Cross border data transfers;
• The rights you have about your personal data;
• The use of cookies; 
• How we protect your personal data; and 
• Policy towards minors.

Please note that this Privacy Policy is provided in the local language. 

We may periodically update this Privacy Policy by posting a new version in our application. If we make any material changes, we will notify you as required under applicable law, including by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

Contact us:

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the support features within the game application, so we can reply to you more quickly. 

Alternatively, you may contact via Email:

Name of Controller: Watchwell Pte. Ltd.

Address: 111, Somerset Road, #16-05, 111 Somerset, Singapore 238164
 Attn: Data Protection Officer
 Email: [email protected]

WHAT INFORMATION DO WE COLLECT:

We collect the following personal data about you: 

Data you provide us directly.

• Contact information (such as name and email address or phone numbers)
• Player name or tag and password
• Profile information (such as profile photo)
• Your messages and other content you submit when you use the Service (such as chat logs and player support tickets)
• Data you provide in connection with surveys, promotions, sweepstakes, competitions and other events, if any. 
• Our payment service providers will collect your payment details in connection with any purchases you make in our in-application store. 

Data we collect automatically.

• Data about your account and game progress.
• Your IP address and mobile device identifiers (such as your device or advertising ID)
• Data about your device, such as device name and operating system, browser type and language, internet service provider, and mobile carrier
• Data we collect with cookies and similar technologies (see more below)
• Approximate location data (as derived from IP address)
• Data about your use of the Service, such as gameplay data, purchases made and your interactions with other players inside the Service

Data we collect from our partners.

We also use third-party partners, such as social networking sites (especially if you log in through their accounts), data analytics providers and advertising networks to supplement information we have about you, such as:

• Data we receive if you link a third-party tool with the Service (such as Facebook and Google)
• Data to fight fraud (such as refund abuse in games)
• Data from platforms that the games run on or data from payment service providers (such as payment verification data)
• Data for analytics purposes (such as surveys), so we can provide you a better Service
• Data that you have made available to us from a third party service (such as Facebook and Google) via your privacy settings

WHY DO WE COLLECT YOUR DATA:

We use your data for a variety of legitimate business purposes, such as:

To perform the contract, we process data necessary to

• Create your personal accounts and allow you to play our games and use our Service;
• Operate the Service;
• Verify and confirm payments, if any;
• Provide and deliver products and services you request;
• Send you Service-related communications.
• To improve the Service for our players.

To provide a better gaming experience and Service to our players, we have a legitimate interest to process necessary data to

• Update and develop player profiles;
• Improve the Service and player experience;
• Manage our relationship with you;
• Provide social features as part of the Service;
• Customize your Service experience;
• Respond to your comments and questions and provide player support;

• Provide you in-app offers in the Service.
• Send you related information via the application, such as updates, security alerts, and support messages;

• Enable you to communicate with other players.

1. To keep the Service safe and fair.

We prioritise creating and ensuring a level  and safe playing field in the game and Service, including the social aspects of it. To achieve this, we have a legitimate interest to process necessary data to

• Analyze and monitor use of the Service and its social features;
• Moderate chats either automatically or manually;
• Take action against fraudulent or misbehaving players.
• To analyze, profile, and segment.

In all of the above cases and purposes and as part of our legitimate interest, we may analyze, profile and segment all collected data.

For other purposes, the basis of the processing would be your consent. Prior to collecting it, we will obtain your consent.

WHO DO WE DISCLOSE YOUR DATA 

We disclose your data to other parties as follows: 

We engage vendors who help us provide the Service. These vendors process your data only at and according to our instructions to provide the Service, and perform tasks such as hosting, player support, advertising, analytics, payments, fraud prevention, illegal activity and other Services. Some of these vendors include our group, affiliated and/or related companies. 

The Service includes features from our partners, such as social media interaction tools, functionalities through application programming interfaces (APIs) or software development kits (SDKs). These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices. If you do not want us to disclose, please do not click on such “sharing” icons. 

These partners may access data regarding your activities and your device (such as your IP address, mobile identifiers, page(s) visited, location, time of day) and may further disclose these data to their advertising partners. 

If you prefer not to share your personal data with Social Media partners, you may follow the instructions in “Your Rights and Options” below.

We may also disclose your data to public authorities in response to valid legal requests out of our need to comply with any legal obligations which we are subjected to, including under any valid court orders. 

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

If we buy or are acquired by a third party as a result of a merger, acquisition or business transfer or we buy or sell any business or asset, your personal data may be disclosed and/or transferred to a third party in connection with such transaction.

Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

INTERNATIONAL DATA TRANSFERS

While our server for users based in European Union is located within the European Union, our operations are international in nature. We engage vendors globally, not just from in Singapore or your country. Your personal data therefore may be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards that we may use include standard contractual clauses and other lawful safeguards, technical or otherwise. 

YOUR RIGHTS AND OPTIONS

You may opt out of receiving promotional communications, such as marketing messages from us by contacting us or by changing your in-game settings (if available). The updated settings may not be effective immediately. Note that you may still continue to receive non-promotional communications from us, such as communications regarding the Service or updates to our Terms of Service or this Privacy Policy.

We may send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.

If you request in writing through the contact method described above under “Contact Us”, we will provide you a copy of your personal data in an electronic format.

You also have the following rights: 

1. right to correct your data; 
2. have your data deleted;
3. object or restrict how we use or share your data or withdraw your consent; and 
4. in certain scenario, the right to be notified if a notifiable data breach has occurred, i.e  if it is likely to result in significant harm to you. 

We will respond to all requests within a reasonable timeframe. If we are unable to respond to your request within thirty (30) days after receiving your request (especially, if your request or the impact thereof is particularly complex or if you have made a number of requests), we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request.

If you continue to have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may also contact your local data protection authority within the European Economic Area for unresolved complaints.

If you wish to exercise any of your data subject rights described above, please write to us in writing through the contact method described under “Contact Us”.

We will respond to all requests in accordance with applicable laws. 

Please note however that we may be required to take steps to verify your identity where applicable before fulfilling your request so as to protect your privacy, such as by requesting you provide us a purchase receipt or other account information, asking you to link your email address with your game account, or asking you to answer questions regarding your activities on our Services. 

You have the right not to receive discriminatory treatment as a result of your exercise of these rights.

COOKIES AND SIMILAR TECHNOLOGIES

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyse use, target advertisements and prevent fraud. Cookies and similar technologies allow us and our partners to store their preferences and track your activities within the Service. Our partners may operate under their own privacy policies.

We and our partners collect and store information about users' interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices or browsers, for instance, and then link those browsers and devices into a device graph. We do so in order to

• detect and prevent fraud;
• allow users to use the Service on one device and pick up seamlessly where they left off on another device;
• analytics, personalization and attribution;
• limit the number of times a user is shown the same advertisement, across all known or inferred devices; and/or
• provide personalized advertising on each device that is inferred from the browsing patterns on all of the devices.

You can disable cookies in your browser settings, but some parts of the Service may then not function properly.

HOW DO WE PROTECT YOUR DATA

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration, such as: 

a. up-to-date antivirus protection;

b. encryption such as TLS/SSL technology;

c.           restriction of access to personnel or service providers on a strictly need-to-know basis, who will only process your information on our instructions and who are subject to a duty of confidentiality and the obligation to protect your personal data to a standard no less than that under Singapore law;

d. logging systems; and 

e.           reviewing our information collection, storage, and processing practices regularly。

We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. We therefore shall not be liable to you for any loss or damage, direct consequential or otherwise, that you may suffer related to the aforesaid, to the extent permitted by law. 

Subject to the below, we retain your data for as long as your account is active or as needed to provide you the Service. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes. We may for example periodically de-identify unused game accounts, and we may regularly review and de-identify unnecessary data.
 

However, after your account has been deleted or if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. 

We endeavour to periodically review the basis and appropriateness of our data retention policy. 

CHILDREN

Generally, our Services are not directed to children under 16 (or other age as required by local law), and the Services do not knowingly collect personal data from children, except as described in the following paragraph.

For games that are not directed at children but nonetheless may appeal to them, we take additional steps to limit access to these Services based on the player’s age. For these Services, when a player indicates they are under 16 (or the applicable age in their territory), we will limit their access to certain features, such as social media and chat features, as well as certain types of notification alerts. We also limit the processing of personal data to only what is necessary to support the internal operations of our Services.

Please note that for some of our Services we may use a higher age limit (such as 18) than described in the above two paragraphs. We do this to provide a safe game experience for our players and to protect Young Players.

If you are a parent or guardian and wish to review personal data collected from your child, or have that information modified or deleted, you may contact us as described above. If we become aware that a child has provided us with personal data contrary to the above, we will delete any personal data we have collected, unless we have a legal obligation to keep it, and terminate the child’s account and/or revert them to the underage experience, as applicable.