PRIVACY POLICY ( Warpportal )

Last updated: May 6, 2021


WELCOME TO GRAVITY INTERACTIVE!

THE USE OF OUR SERVICES AND WEB SITES IS SUBJECT TO AGREEMENT TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE THE TERMS OF OUR PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR SITES.


OUR PRIVACY COMMITMENT

The Gravity Interactive, Inc., its subsidiaries, and affiliates (collectively, "Gravity Interactive") respect the privacy rights of our online visitors and recognizes the importance of protecting all information that you may choose to share with us. To further this commitment, we have adopted this Online Privacy Policy ("Privacy Policy") to guide how we collect, store, and use the information you provide us.


TABLE OF CONTENTS

Q1. What information does this Privacy Statement cover?
Q2. What types of personally identifiable information do we collect about our users?
Q3. How is your personally identifiable information used and shared?
Q4. What choices do you have about the collection, use, and sharing of your personally identifiable information?
Q5. What kinds of security measures do we take to safeguard your personally identifiable information?
Q6. How can you update your personal information and profile?
Q7. How can you ask questions, or send us comments, about this Privacy Policy?
Q8. How will you know if we amend this Privacy Policy?
Q9. What are the application areas of this Privacy Policy?

Q1. What information does this Privacy Statement cover?

A1. This Privacy Policy applies only to personal information collected on the websites where this Privacy Policy is posted, and does not apply to any other information collected by Gravity Interactive through any other means.

This Privacy Policy applies to use and sharing of personal information collected on and after the date that this Privacy Policy is posted.

Please note that this Privacy Policy applies only to information submitted and collected online and does not apply to information that may be collected by Gravity Interactive offline. This Privacy Policy applies only to websites maintained by Gravity Interactive, and not to our international affiliates or any websites maintained by other companies or organizations to which we link. Gravity Interactive is therefore not responsible for the content or activities provided on those websites.

Finally, the terms of this Privacy Policy are subject to all applicable laws.



Q2. What types of personally identifiable information do we collect about our users?

A2. We don't require personal information to access our website. However, if you prefer not to disclose personal information, you will not be able to enjoy certain features of our website. Personal information is information that identifies you and may be used to contact you. To offer our users certain features on our website, we collect several types of personal information.

Children
Our Terms of Agreement specify that memberships are available only to individuals who are 16 years of age or older. If you are under the age of 16, you may not create an account on the Sites, you may not sign up for any subscription service or buy anything through the Store, and you are not eligible to enter any of our sweepstakes or promotions.

Except as may be required by law, Gravity Interactive will not knowingly collect, maintain, or disclose any personal information from children under the age of 16. We take children's privacy seriously and encourage parents to play an active role in their children's online experience at all times.

Where the consent of a parents or guardian is required for the collection of personal information pursuant to relevant rules and regulations, you shall obtain consent from your parents or guardians.

Gravity Interactive recommends that parents and guardians spend time online with their children to become more familiar with the types of content available on the Internet, including our online games.

Parents and guardians should regularly oversee their children's use of email and other online communications and transactional features. Control tools are available from online services and software manufacturers that can help provide a safe online environment for kids.


Information You Provide to Us
All of the personal information we receive comes directly from our users. We collect personal information from our users to:
1. Register for our website
2. Subscribe to our newsletter
3. Join our message boards and forums
4. Participate in polls, surveys, and questionnaires
5. Participate in contests, sweepstakes, or other promotions
6. Use e-cards, wish lists, and tell-a-friend features
7. Purchase a product at one of our online stores
8. Offer feedback or other business inquiries
9. Receive customer or technical support

Typically, this information includes:
1. Name
2. Email address
3. Telephone number
4. Shipping and billing address, and
5. For those purchasing products online, credit card information.
Additionally, we may also collect demographic information such as your age or date of birth, gender, hobbies, occupation, platform preferences, and other game ownership and preferences. This demographic information may be associated with your personal information.

Information Collected Through Technology
We collect information through technology to make our websites more interesting and useful to you. For example, when you come to one of our websites, we collect your IP address. An IP address is often associated with the portal through which you enter the Internet, like your ISP (Internet service provider), your company, or your school. Standing alone, your IP address is not personally identifiable. At times, we also use IP addresses to collect information regarding the frequency with which our users visit various parts of our websites. We may combine this information with personally identifiable information.

Cookies
Our websites also use cookies. Cookies are pieces of information that a Website sends to your computer while you are viewing the Website. We and other companies use cookies for a variety of purposes. For example, when you return to one of our websites after logging in, cookies provide information to the website so that the website will remember who you are. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can do this through your browser (like Netscape Navigator or Internet Explorer) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won't have access to many features that make your web experience smoother, like the features mentioned above, and some of our services may not function properly.

Web Beacons
Our websites use a variety of technical methods for tracking purposes, including web beacons. Web beacons are small pieces of data that are embedded in images on the pages of websites. We also use these technical methods to analyze the traffic patterns on our websites, such as the frequency with which our users visit various parts of our websites. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We also use these technical methods in HTML emails that we send our users to determine whether our users have opened those emails or clicked on links in those emails. The information from use of these technical methods may be collected in a form that is personally identifiable.



Q3. How is your personally identifiable information used and shared?

A3. We don't share, sell, or rent your personal information to third parties without your consent. We don't require personal information to access our website. However, if you prefer not to disclose personal information, you will not be able to enjoy certain features of our website.

Whatever the purpose may be, we will only collect information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives.

Gravity Interactive Tools and Updates
Information collected from those who voluntarily submit it to us is used to provide services like newsletter subscription, updates on special events, game news, and email announcements of interest to our users. Moreover, if you register for access to our blogs or message boards, we will use your personal information to enable you to view and post messages on the boards. However, you should understand that community forums, blogs, and message boards are tools that allow you to communicate with members of the online community. As such, whenever you give out personal information in public areas, that information can be collected and used by people you don't know.

Third Parties' Use of Personal Information
Occasionally, we share your personal information (e.g., email address) with a third party sponsor, co-sponsor, or other reputable third party that provides products or services that may be of interest to you. We may use other companies, agents or contractors to perform services necessary to our operations. For example, we have partnered with other companies to personalize our web pages, process credit card transactions, analyze customers' interaction with our website, and process consumer surveys. We also provide postal addresses to the U.S. Post Office for delivery purposes. In the course of providing such services, these companies may have contact with your personally identifying information. We will attempt to ensure that these entities do not use your personal information for any other purpose, and that they have agreed to maintain the confidentiality, security, and integrity of the personal information they obtain from us.

Operational Uses
We may also use your personal information for other purposes such as "Operational Uses." For example, we may use your information to send you administrative communications either about your account with us or about features of our websites, including any future changes to this Privacy Policy.

Aggregate Information
Finally, we may take your personally identifiable information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, no restrictions apply under this Privacy Policy on our right to aggregate or de-personalize your personal information, and we may use and share in any way with third parties the resulting non-personally identifiable information.

Business Information
For practical reasons, we treat personal information submitted to us in a business capacity different from information we receive in a non-business capacity. Personal information submitted to us in a business capacity (e.g. resumes, event sponsorship, etc.) may be shared with third parties, depending on the nature of the inquiry.

Purchase or Sale of Businesses
From time to time, we may purchase a business or sell one or more of our businesses and your personally identifiable information may be transferred as a part of the purchase or sale. If we purchase a business, the personally identifiable information received with that business would be treated in accordance with this Privacy Policy, if it is practicable and permissible to do so. If we sell a business, we will include provisions in the selling contract requiring the purchaser to treat your personally identifiable information in the same manner required by this Privacy Policy (including any amendments to this Privacy Policy). The provisions of this paragraph will also apply if we are sold as part of bankruptcy proceedings.

Disclosures Required By Law and Disclosures to Help Protect the Security and Safety of Our Websites and Others
We will disclose personal information when we believe in good faith that such disclosures (a) are required by law, including, for example, to comply with a court order or subpoena, or (b) will help to: enforce our Terms of Use; enforce contest, sweepstakes, promotions, and/or game rules; protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of our websites or third parties.



Q4. What choices do you have about the collection, use, and sharing of your personally identifiable information?

A4. As mentioned above, you have control over the personal information you submit to us. If at any time you decide to remove your personal information from our database, you may do so by emailing us at privacy@gravityus.com , or write to Privacy Policy Administrator, Gravity Interactive Inc. P.O. BOX 2188 Buena Park, CA 90621

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, click here.



Q5. What kinds of security measures do we take to safeguard your personally identifiable information?

A5. The security and confidentiality of your information is extremely important to us. We have implemented technical, administrative, and physical security measures to protect your personal information from unauthorized access and improper use:
• User data is stored behind a firewall.
• Data is stored in a secure physical environment. (e.g. behind locked doors)
• Data is stored in a database accessible to authorized employees on a need-to-know basis only.
• Users or employees must have a unique password before gaining access to user data.
• We use standard encryption technology when transferring or receiving sensitive personal information like credit card numbers.
• We maintain written security policies to which all employees must adhere.

From time to time, we review our security procedures to consider appropriate new technology and methods. However, please understand that, despite our best efforts, no security measure is perfect or impenetrable.



Q6. How can you update your personal information and profile?

A6. You can access and update the contact information you gave us during registration (that is, your e-mail address or any other information that would directly enable us to contact you), by accessing your online profile or emailing us at privacy@gravityus.com



Q7. How can you ask questions, or send us comments, about this Privacy Policy?

A7. If you have questions or wish to send us comments about this Privacy Policy, please send us an e-mail us with your questions or comments to call or write us at:
Gravity Interactive, Inc.
Attn.: Privacy Policy Administrator
P.O. BOX 2188
Buena Park, CA 90621
(714) 736 - 3487
privacy@gravityus.com
Please be assured that any personal information that you provide in communications to the above email and postal mail addresses will not be used to send you promotional materials, unless you request it.



Q8. How will you know if we amend this Privacy Policy?

A8. We may amend this Privacy Policy at any time. If we make any material changes in the way we collect, use, or share your personal information, we will notify you by sending you an email at the last email address that you provided us, or by prominently posting notice of the changes on the websites covered by this Privacy Policy. Any material changes to this Privacy Policy will be effective 30 days following our dispatch of an email notice to you or 30 days following our posting of notice of the changes on the Websites covered by this Privacy Policy.

Please note that, at all times, you are responsible for updating your personal information to provide us your current email address. If the last email address that you have provided us is not valid, or for any other reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice.



GRAVITY INTERACTIVE, INC.

PRIVACY POLICY (For EEA and UK Residents)

(Effective Date: April 31st 2021)


1. Introduction

We take privacy seriously, and we are committed to protecting personal data (the "Personal Data") of our users ("you" or "User") who reside in the territory of the European Economic Area (EEA) which includes the European Union member states and Iceland, Liechtenstein, and Norway. This policy also covers our users who reside within the United Kingdom.

This Privacy Policy (the "Policy") is based on the principles set forth under the General Data Protection Regulation (GDPR) (and any other applicable law mandating data protection/GDPR) and describes the full scope of purposes and reasons for collecting and processing of Personal Data. This privacy policy also determines and limits what Personal Data we collect and how we use it (several sections below), how long we store it (is covered in each section devoted to the specific data), who has access to it, and what rights and other control mechanisms are available to you as a User.

This Policy applies where we are acting as a data controller concerning your data and is limited to data collected or received by us through your use of our Services (defined hereinafter).


2. Who We Are

Gravity Interactive Inc. ("Controller"), with Controller's affiliates and independent contractors ("Co-Providers", collectively with Controller, "us," "our," or, "we"), provide PC online games ("Game") and related services, including, without limitation, online communities for Game or Social Networking Services offered by us via warpportal.com or our branded websites ("Sites") (collectively, our "Service(s)"). For clarity, the specific list of Controller's affiliates and Co Providers are as followed.


Name

Address

Role

Gravity Co. Ltd.

R&D Tower 15F, Nuritkum Square, 396 Worldcup Buk-ro, Mapo-Gu, Seoul, Korea

IP Holder

Co-Developer


The Services for our Game includes Sites, without limitation, such as online communities for Game or Social Networking Services offered by us via warpportal.com or our branded websites. The specific list of our Sites is as followed.

Name

Address

warpportal.com

http://warpportal.com/

Dragon Saga

http://www.playdragonsaga.com/


The Personal Data is processed by:

Company Name: Gravity Interactive, Inc.

Official Address: 7001 Village Drive Buena Park, CA 90621, California

Phone: 714-736-3415

Contact Email: warpportalmobile@warpportal.com

The EU Representative of Controller under Art. 27 GDPR can be reached at:

Company Name: The DPO Centre (Europe) Ltd.

Official Address: Alexandra House, Ballsbridge Business Park, Ballsbridge Park, Merrion Road, Dublin, Ireland, DO4 C7H2

Phone: +353 1 631 9460

Contact Email: EURep@warpportal.com

The UK Representative of Controller under UK GDPR can be reached at:

Company Name: The DPO Centre Ltd.

Official Address: The DPO Centre, 50 Liverpool Street, London, EC2M 7PY, UK

Phone: +44 (0) 203 797 1289

Contact Email: UKRep@warpportal.com

Further, our data protection officer can be reached at:

Name: Martin Ok

Email: warpportalmobile@warpportal.com

Address: Sangam-Dong, Nuritkum Square R&D Tower 15F, 396, World Cup buk-ro, Mapo-gu, Seoul, Korea


3. Processing of Personal Data

We process your Personal Data when they are strictly necessary for the following purposes:



3.1 Performance of our Services


We process your Personal Data on the lawful basis of performance of the agreement concluded between you and us in order:


    • to provide our Services to Users namely: registration (creation) and operation of Game account, providing access to the Game account, formation and performance of the agreement with us on using the Services, providing the Game, the Services and Game access to Users, sending, processing of and responding to support tickets along with other communications with us, payment acceptance;
    • to enhance the security and safety of your Game accounts;
    • to communicate with you about transactions made by you while using our Services or Game, as well as to send you notifications related to your account security such as notifications about password recovery requests, editing security settings, changing of e-mail or profile settings and similar;
    • to send you information about updates in our Services or Game, about features on our Sites, about upcoming events (online and offline) and other information related to our Services or Game (in case you have not unsubscribed);
    • to inform you about changes in our policies and legal documents;
    • to communicate with you to resolve any problem you faced while using our Services or Game;
    • to inform you about our activities (in case you have not unsubscribed); for developing new tools, products or services for you;
    • to provide support, as well as technical support, including, but not limited to, Game and Services updates, product patches and fixes and other similar communications;
    • to restore access to the User's account, Services and/or to the Game;
    • to restore lost payments made by the User to improve our Services and Game, as well as while requesting your feedback about our Services and Game;
    • to provide you with information, Services, and the Game available at or intended for the territory where you are;
    • to send notifications or communications related to access to Our Services and/or the Game, password restoring or otherwise restoring access to the User's account. You can disable this feature at any time, though you will be unable to use such features.


For these purposes, we process the following Personal Data:


• Compulsory Data that is processed in all events:


    • User's ID in the Social Networking Services that is Used for Registration at Warpportal (If Applicable)
    • Correspondence with User, including Support Tickets along with Other Communications
    • IP address


Compulsory Data is required for us to provide Services and the Game to Users and perform other obligations under the agreements concluded with Users. Request for erasing of such data may result in your inability of using our Services as set forth in below.


Compulsory Data may be collected through, namely:

• through registration with Services and/or with the Game;

• while contacting us via e-mail, phone or mailing address of ours;

• while contacting our support team or otherwise;

• while using the forum, chats related to Services and/or the Game;

• while using Services and/or the Game otherwise (including information you provide to when participating in competitions, contests, and tournaments or responding to surveys, e.g. your contact details);


We also process anonymous data to analyze and produce statistics related to the habits, usage patterns, as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates.


If we find that you provided incorrect or inaccurate Personal Data, it may restrict (ban) your Game account until you amend it.


3.2 Payment


When the User tops up his or her Game account or makes payments via Payment Gateway such as PayPal or Boa Compra (the "PG"), we and the Payment Gateways that is chosen by the User to process the payment exchange with the following Data:


• User ID from our Billing System

• User ID in the Payment Gateway

• Payment ID (Transaction/Order)

• Date and Time of Payment (Transaction/Order)

• Amount of Payment (Transaction/Order)

• Currency of Payment (Transaction/Order)


When the User use credit cards for payment purposes, the Data required are:


• Name of the Cardholder

• Credit Card Number

• Country Code (if applicable)

• Address (if applicable)


Such Data regarding credit card payment as mentioned is provided by the User directly to the payment systems under the terms of use of such system that the system may require Users to enter before processing the payment. We do not process such Data.



3.3 Promotion


We process Personal Data on the lawful bases of consent and legitimate interests pursued by us or a third party (e.g., the interests of other customers of ours), except where such interests are overridden by your prevailing data protection rights and if you have withdrawn your consent, to send promotional or marketing information and news about the planned contests, promotions and similar events, news about our Services and the Game.


If you do not wish to receive such information, you can unsubscribe from receipt of such information following the instructions as described in the corresponding messages or Game account interface.


We also process Personal Data on the same lawful basis in order to manage Users' relationships and organization, follow-up, communication, subscription and invitations relating to competitions, events or game tournaments organized or supported by us (for example, communication with you when you take part in online or offline competitions, events or game tournaments organized or supported by us or arrange your travel, receipt of gifts and awards, to which you may be entitled as a result of winning in online or offline competitions or events, etc.).



The scope and purpose of the processing of your Personal Data, among other conditions for the processing, is specified in this Policy. We will notify you about any changes in our Policy.


Process of Non-Personal Data for improvement and development


To provide quality Services and to justify your expectations of Our Services and/or Game, we collect anonymous data:


• Name and Version of the Operating System

• Size of RAM

• Size of Available Disk Space

• Parameters of the Network Channel and Internet Connection such as Network Bandwidth and Delay from User's Computer to our Servers, Traceroute Information between Your PC and Our Servers, etc.

• Other Data that is Mentioned in the Technical Requirements to the Game


We collect information about your Game' preferences, progress in Game, playtime, as well as information about device settings, unique device identifiers, and crash data. We process and store such data also to evaluate development plans, provide updates to the Services and Game, bug-fixing.

Such information, is stored for the validity period of relevant agreements with us and 1 year after the termination of such agreements unless there is a legitimate reason for a longer processing.

Be also aware, that for the purpose of organization of game process, we collect information about your in-game activities, logs, and data on in-game transactions. Such data also used for Game violations detections (as well as Sites violations) to prevent or punish for cheating and unfair gaming behavior. This data is used for detection, investigation, prevention and, where applicable, and stored only for the minimum amount of time needed for this purpose. If the data indicates that a violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such violations. Also be aware that enjoying a certain User's rights shall be in balance with rights and interests of other Users and should not affect the rights and freedoms of other parties.


3.4 Prevention of illegal behavior


We process your Personal Data on the lawful basis of compliance with legal obligations that we are subject to in order:


  • To prevent the illegal use of our Services and the Game if there is reason to believe that there is a risk to security of Our Servers (i.e. blocking of concurrent IP addresses).


For this purpose, the Data processed is:


- IP address


  • To prevent illegal user's access


For this purpose, the Data processed is:


  • Organization of the Game Process
  • Information about your In-game Character Activities, Logs, and Data on In-Game Transactions
  • Game Data and Commands the so-called Log Files (Information on the Actions Made by the Character in the Game Generated by the Software, Fixed in Symbolic Non-Personal Form)


We use this data for decisions to ban a Game account or user's character, according to the rules of the relevant Game.


In the event of litigation between the User and us or in case we receive a request from competent authority, such data can be combined with the personal information you provide and are stored during the period of resolution of the dispute.



4. Security Measures

Our endeavors to implement technical and organizational measures to protect your Personal Data against accidental or unlawful destruction, alteration or loss, unauthorized disclosure, or access. We, affiliates and third parties authorized to access the Personal Data, are required to give the undertaking to maintain such confidentiality and secrecy.


Among other measures, any information sent to us is encrypted (scrambled) using high qualified technology. This is industry-standard encryption technology that protects your data while being sent over the Internet from being intercepted and misused by third parties.


We have put in place, and regularly reviews and updates, appropriate physical, electronic, and managerial procedures to keep the data safe and help prevent unauthorized access, maintain data security and correctly use the information collected.


Should we become aware of a data breach we will take all relevant actions and steps necessary to rectify the breach. We will also notify the relevant supervisory authority and individuals (if required under the GDPR and other applicable data protection laws) and work with other parties as required to ensure any breaches are remedied and there is no other compromise of personal data.



5. Sharing of User's information

We do not transfer your data to anyone, except for those specified in this Policy or as provided by the rules into force. This is related to the provision of Our Services and performance of contracts you have concluded with us. If such transfer to third parties is related to any other purpose, we will notify you of such transfer.


We do not sell your personal information and does not receive benefits from any treatment of your data. We do not use your data for advertising or promotion of products and services of third parties.



(1) Regarding Payment systems, we share your Personal Data such as:


Email address, IP address, information about in-game purchases, and other information you provide to us for the purpose of fulfilling your purchase. The list of payment methods (payment systems, payment agents) that may be used by the User for payments and with which we may share your data are described at our Sites. The specific list of the entities who access the Personal Data to process the payment, the place where the transferred Personal Data is stored and the relevant contract name based on which the Personal Data is transferred are as followed.

Name

Data Storage Place

Transferred Data

Relevant Contact

PayPal

USA

Information about payment

https://www.paypal.com/us/webapps/mpp/ua/privacy-full

Razer

USA

Information about payment purchases

https://www.razer.com/legal/customer-privacy-policy

Xsolla

Netherlands /USA

Information about payment

https://xsolla.com/privacypolicy

Boku

USA

Information about payment

https://www.boku.com/payments-privacy-notice/

GoCash

USA

Information about payment

https://gocashgamecard.net/terms-of-service

Smart2Pay

Rotterdam

Information about payment

https://smart2pay.com/en/Privacy


(2) With data storage partners, we share your Personal Data


Some of the information is stored using third-party data storage services. We provide personal information to our affiliates and other trusted businesses or persons to process it for us, in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. The specific list of the entities whose information storage service is used for the custody of Personal Data, the place where the transferred Personal Data is stored and the relevant contract name based on which the Personal Data is transferred are as followed.


Name

Data Storage Place

Transferred Data

Relevant Contact

CoreSite Data Center LA2

900 N Alameda St STE 200, Los Angeles, CA 90012

Information about user's billing and game data

https://www.coresite.com/privacy


The data is stored separately. Your data may be combined with other data collected by us in exceptional cases, for example, in case of a violation by users of the agreement with us or the rules of the game, the availability of a dispute between us and the User, conduct of financial control and accounting, etc. As for the detecting violations, be aware that we use anti-cheating tools that collect information about the processes in use while you are accessing Game.


The User can modify and/or erase the data provided to them, except for those specified in this section as unalterable. The user may edit his personal information having access to his private account. All changes are logged.


(3) For publicly available information


Our Sites may also have message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum, or chat area, please be aware that the information is being made publicly available on-line; therefore, you are doing so at your own risk. If your personal information is posted on one of our community forums and you want to remove such information, please inform us with request to its removal.



(4) With Anti-cheat and anti-fraud companies,


We share the information required for our detection, investigation, and prevention of cheating in the Game and violations of agreements related to the Game only for the purposes of detection, investigation, and prevention of cheating in the Game.



(5) When our control is changed


We may share your data as part of our company's sale, merger or change in control, or preparation for any of these events. Any entity which buys us, or part of our business will have the right to continue using your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.


6. Retaining and Deleting Personal Data

We retain your Personal Data only for the period of time as necessary to achieve the particular purpose for which the information was processed. Typically, without your request to erase Personal Data and also without legitimate reason to keep it longer, after the termination of our relationship, we retain your information for 1 month after deregistration of your Game Account or for the duration described in the table below:


Personal Data Retained

Retention Period

Data necessary for performance of the agreement or cancellation of subscription

Records of payment

Records of electronic financial transaction


5 years

Records of a customer complaint or dispute resolution

Records that Game account or character was banned based on the violation.


3 years

Records of correspondence with User; to support Users in using the Services and the Game; to ensure security and confidentiality of the User's account and data; to restore access to the User's account, Services and/or to the Game; to restore lost payments made by the User.


3 year unless stipulated more specifically in other agreements

Record of User's; progress in Game, and playtime

For as long as a character is being used in game

Record of in-game character activities, logs, and data on in-game transactions, log-files and in-game chats.


Records of misuse by users of Game or Services


3 years

Computer communication or internet log-in records of computer communication or facts about an internet user's utilization of telecommunication service


3 years


For the clarity, we retain your information insofar as such information will be processed solely for archiving purpose in the compliance with our legal obligation or statistical purposes, subject to appropriate safeguards, in accordance with the data protection laws, for your rights and freedoms. The appropriate safeguards shall ensure that technical and organizational measures are in place to ensure respect for the principle of data minimization.


7. Age to use our Services

You must be at least 16 years of age to use our services and we do not knowingly collect any personal information from children under the age of 16. If we learn that we have inadvertently gathered Personal Data from those under the age of 16 we will take reasonable measures to promptly erase such information from our records.

If we also are informed that anyone under the age of 16 is using our services through a parent or other legal guardian, we will we will take reasonable measures to promptly erase such information from our records.

If someone is suspected of using our services and is under the age of 16 we may also look to ban them from using our services.

You can contact us at EURep@warpportal.com to inform us if someone under 16 years old is using our services at any time.


8. Your Privacy Rights


(1) Right to Access

You are entitled to confirmation as to whether or not we process your Personal Data and, where we do, access to the Personal Data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Data concerned, and the recipients of the Personal Data. We will supply you a copy of your Personal Data. You can access your Personal Data by logging into your Game account or contacting us at EURep@warpportal.com or UKRep@warpportal.com

(2) Right to Rectification

You are entitled to have any inaccurate Personal Data about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about you completed. You may change or update the profile information by logging into your Game account or by contacting us at EURep@warpportal.com or UKRep@warpportal.com


(3) Right to Erasure

In some circumstances, you are entitled to the erasure of your Personal Data without undue delay. Those circumstances include: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing; (iii) you object to the processing; (iv) the Personal Data must be erased to comply with a legal obligation and (v) the Personal Data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: (a) for exercising the right of freedom of expression and information; (b) for compliance with a legal obligation; (c) for public interest or (d) for the establishment, exercise or defense of legal claims.

If you choose to terminate or delete your Game account, we will immediately delete your Game account information.

If a User requests the erase of the Personal Data, while a prior request (s) from that User is still being processed, such data can be erased only when the User has recalled/canceled all previous requests.

You may request the erasure of your information by visiting the Sites or by contacting us at EURep@warpportal.com or UKRep@warpportal.com

(4) Right to Restrict Processing

In some circumstances, you are entitled to restrict the processing of your Personal Data. Those circumstances are: (i) you contest the accuracy of the Personal Data; (ii) processing is unlawful, but you oppose erasure; (iii) we no longer need the Personal Data for the purposes of our processing, but you require Personal Data for the establishment, exercise or defense of legal claims; and (iv)during the verification of the prevalence of the legitimate interest that we pursue regarding the Personal Data processing on yours. Where processing has been restricted on this basis, we may continue to store your Personal Data. However, we will only otherwise process it: (a) with your consent; (b) for the establishment, exercise or defense of legal claims; (c) for the protection of the rights of another natural or legal person; or (d) for reasons of important public interest.

You may request the restriction of the processing of your information by visiting the Sites or by contacting us at EURep@warpportal.com or UKRep@warpportal.com

(5) Right to Object to Processing

You have the right to object to our processing of your Personal Data, at any time, on grounds relating to your particular situation, but only to the extent that the lawful basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You may object to the processing of your information by visiting the Sites or by contacting us at EURep@warpportal.com or UKRep@warpportal.com

(6) Right to Object to Processing for Direct Marketing Purposes

You are entitled to object to our processing of your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your Personal Data for this purpose.

You may object to the processing of your information for direct marketing purposes by visiting the Sites or by contacting us at EURep@warpportal.com or UKRep@warpportal.com

(7) Right to Object to Processing for Statistical Purposes

You have the right to object to our processing of your Personal Data for statistical purposes. We do statistical processing for analyzing game data for analysis and optimization of the service and advertising campaigns which can include the users device or IP information.

You may object to the processing of your information for statistical purposes by visiting the Sites or by contacting us at EURep@warpportal.com or UKRep@warpportal.com

(8) Right to Data Portability

To the extent that the lawful basis for our processing of your Personal Data is:

• consent; or

• that the processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract, and such processing is carried out by automated means, and you have the right to receive your Personal Data from us in a structured, commonly used and machine-readable format and the right to have your Personal Data transmitted to another controller.

You may request to receive your information by visiting the Sites or by contacting us at EURep@warpportal.com or UKRep@warpportal.com


(9) Right to Complain to a Supervisory Authority

If you consider that our processing of your Personal Data infringes data protection laws, you are entitled to file a complaint with a supervisory authority responsible for data protection.

You can find more details of the supervisory authority in your country by visiting

http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

For the UK: https://ico.org.uk/make-a-complaint


(10) Right to Withdraw Consent

To the extent that the lawful basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may withdraw your consent at any time in the Game setting or contacting us at warpportalmobile@warpportal.com.

You may also exercise any of your rights concerning your personal data by written notice to us at EURep@warpportal.com or UKRep@warpportal.com

9. Change/Update to Privacy Policy

We may amend, at our discretion, any portion of this Privacy Policy at any time by posting or displaying the amended Privacy Policy within and/or on the Sites. We request your reading confirmation for each of these amendments. Except as otherwise stated, any such amendments will be automatically effective after they are initially posted. We will notify you about any significant changes in our Policy. This policy was last updated on April 31, 2021.


10. Links

The Service may contain links to other websites. The fact that the Service links to a website or presents a banner ad or other type of advertisement does not mean that we endorse or authorize that third party, nor is it a representation of our affiliation with that third party. We are in no way responsible for the privacy policies of these other websites to which you choose to access from the Services. It is your responsibility to read the privacy policies of these other websites when exiting the Services.


11. Questions

If you have any questions regarding our Privacy Policy and/or practices, please email us at EURep@warortal.com or UKRep@warpportal.com or warpportalmobile@warpportal.com.


TERMS OF SERVICE ( Warpportal )

Last updated: May 6, 2021


1. TERMS OF AGREEMENT

This Agreement applies to websites operated by Gravity Interactive, Inc. (The "Company" and/or "Gravity") including but not limited to warpportal.com (the " Sites"). In addition, the Company owns several other domain names that point to the Sites listed above, and the Company will from time to time add new Sites that may or may not be listed above. Please note that this Agreement applies only to sites maintained by the Company and not to websites maintained by other companies or organizations to which we link.

BEFORE PROCEEDING TO REGISTER, PLEASE READ THE TERMS OF SERVICE AND CHECK THE "AGREE" BOX IF YOU ACCEPT THE TERMS. BY CLICKING ON THE "I AGREE" BUTTON, INSTALLING, COPYING, OR OTHERWISE USING THE GAME, YOU AGREE TO BE BOUND BY THE TERMS OF THIS AGREEMENT. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS AGREEMENT, PLEASE CLICK ON THE "I DO NOT AGREE" BUTTON AND PROMPTLY LEAVE THIS PAGE AND DO NOT USE OR ACCESS OUR SITES OR SERVICE.

ACCESS AND USE OF OUR APPLICATIONS OR RELATED PRODUCTS OR SERVICES BY CHILDREN UNDER THE AGE OF 16 IS STRICTLY PROHIBITED.



2. DEFINITIONS

(a) "Intellectual Property" shall mean all patents, designs, utility models, copyrights, know-how, trade secrets, trademarks, service mark, trade dress and any other intellectual property rights in or related to the Game or Technical Information.

(b) "Technical Information" shall mean the software, know-how, data, test result, layouts, artwork, processes, scripts, concepts and other technical information on or in relation to the Service and the installation, operation, maintenance, service and use thereof.

(c) "End Users" shall mean the users of the Service through network game service system established and operated with individually assigned ID numbers for each End User.



3. AMENDMENTS

This User agreement (the "Agreement") comprises the entire agreement between Gravity and the User, and supersedes any prior agreements between the User and Gravity with respect to the subject matter hereof. This Agreement does not supersede any additional terms and conditions of which User is notified by Gravity and/or which may apply when using third party content or services. Gravity may amend or revise this Agreement at any time and at its sole discretion, and such amendment or revision shall be effective upon posting of such revised agreement on the Sites. User hereby agrees to review this Agreement by accessing the Site periodically to become aware of any such revisions. If any revision is unacceptable to the User, the User may terminate the Agreement hereof. Continued use of the Services following the posting of the revised Agreement shall be deemed to be acceptance of all such revisions.



4. DESCRIPTION OF SERVICE

The Company offers various games as a free online game service (the "Service") accessible via the internet at the Sites with sales of various game items for your additional interest. Secondly, it reserves the right to change the URL address of the website at any time upon necessity. In order to use the Service, you need to download the software available on its Sites for an installation of the necessary components (the "Software"). Furthermore, an establishment of a policy (the "Policy") is necessary for those who wish to use the subject service, and the Company shall not be responsible for any fees and charges incurred in any, if not all, of an establishment/usage/termination of your Internet Service. The Sites is an active part of the Service, and any use of the Site shall be governed by the same terms and conditions of this Agreement and the Rules of Conduct.



5. USER'S OBLIGATIONS AND RESPOSIBILITIES

In order to use the Service, you are required to complete a registration form containing your nickname, gender, date of birth, e-mail address, and a password. In consideration of the use of the Service, you agree to provide true, accurate, current and complete information about yourself as submitted in any registration form on the Service and to maintain up-to-date information which is true, accurate, current and complete at all times by making changes, additions or deletions to your User profile, as required. If any information provided is not true, accurate, current or complete, or Gravity has reasonable grounds to suspect that the information is untrue, inaccurate, not current or complete, then Gravity shall have the right to suspend or terminate your right to use the Service and refuse to provide any current or future Service to you.

You acknowledge that Gravity reserves the right to refuse to grant you a user name that is already in use, may be illegal, may be protected by trade-mark or other proprietary interest, is obscene or profane or otherwise determined by Gravity, in its sole discretion, to be inappropriate. You agree to be responsible for all acts and omissions that occur in connection with your password. You agree to keep your password confidential and to notify Gravity if you believe that the security of your password has been compromised. You acknowledge that Gravity does not protect you from the unauthorized use of your password.

(a) Eligibility. Gravity's Services are available only to individuals who are sixteen (16) years of age and older. Individuals under the age of sixteen (16) may not use any Gravity Sites; may not create an account for or use any of Gravity's Services; may not make any purchases through Gravity's Store; and are not eligible to enter any of our sweepstakes or promotions.

Accounts are not available to individuals who are not allowed to receive products, including Services or Software, from the United States (for example if you are located in a country embargoed by the United States or if you are on the U.S. Treasury Department's list of Specially Designated Nationals or the U.S. Department of Commerce Denied Persons List or Entity List). By using this Service, you represent and warrant that you are not located in any country embargoed by the United States or on the U.S. Treasury Department's list of Specially Designated Nationals or the U.S. Department of Commerce Denied Persons List or Entity List.

Those who have completed these steps and who maintain their Account in good standing are sometimes referred to in this Agreement as "Members." By clicking the "Agree" button you represent that you are a 16 years of age or older. Only one person may use an Account. You are liable for all activities conducted through your Account, and parents or guardians are liable for all activities of their minor child under rules and regulations, even if who are over 16 years old, conducted through the Account. If you are minor under the relevant rules and regulations, you should obtain consent from your parents or guardians.

Except as may be required by law, Gravity Interactive will not knowingly collect, maintain, or disclose any personal information from children under the age of 16. Gravity Interactive recommends parents and guardians to spend time online with their children to become more familiar with the types of content available on the Internet, including our online games. Parents and guardians should regularly oversee their children's use of email and other online communications and transactional features. Control tools are available from online services and software manufacturers that can help provide a safe online environment for kids.

(b) Account ID. Your email address is your account ID. As creator of your Account ID, you are completely responsible for your identity and Gravity will not tolerate offensive, obscene, or otherwise inappropriate Account ID. If an Account ID violates any part of these Terms, determined at the sole and absolute discretion of Gravity support personnel, we may immediately, temporarily, or permanently ban the associated User Account from the Sites and Service, with or without notice or prior warning.

(c) Account. By agreeing to the User Agreement you agree that you do not own the account you use to access the Service, the characters that Gravity stores on its servers, the items stored on these servers, or any other data which the servers and accounts are comprised of. The account you create is needed to login to the service and the fee that you pay is to continue to access the service.

(d) Nickname. In order to use the Service, you must create a Nickname to identify you to other Members (your "Nickname"). You may not select as your Nickname the name of another person, or a name which violates any third party's trademark right, copyright, or other proprietary right, or which may mislead other Members to believe you to be an employee of Gravity, or which Gravity deems at its sole discretion to be vulgar or otherwise offensive. Gravity reserves the right to delete, or alter any vulgar or otherwise offensive Nicknames.

(e) Pledge Names, Pledge Titles, House Signs, Individual Titles, NPC Names. While accessing the service, it is possible to name your pledge, grant titles to individual members, grant a title to your own character, and name NPCs. You may not give a name to a pledge, another character, grant your own character a title, or name an NPC (non player character) that is the name of another person, or a name which violates any third party's trademark right, copyright, or other proprietary right, or which may mislead other Members to believe you to be an employee of Gravity, or which Gravity deems at its sole discretion to be vulgar or otherwise offensive. Gravity reserves the right to delete, change, or require you to change, any vulgar or otherwise offensive Name.

(f) Passwords. At the time your Account is opened, you must select a password. You are responsible for maintaining the confidentiality of your password and you are responsible for any harm resulting from your disclosure or allowing the disclosure of your password or from use by any person of your password to gain access to your Account and Account ID. At no time should you respond to an online request for a password. Gravity will never ask for your password offline or online, except that you will be required to enter your password as part of the log-on process.

(g) Former Members. Members whose Accounts have been terminated by Gravity may not access the Service in any manner or for any reason, including through any other Account, without the express written permission of Gravity.

(h) Related Accounts. If Gravity terminates an Account, Gravity may terminate any other Accounts that share the same member name, phone number, email address, postal address, Internet Protocol address, or credit card number with the terminated Account.



6. CHARGES FOR SERVICE

(a) General Charges. Current fees for using the Service are published in the billing section of the Site. All fees are stated in U.S. Dollars. Gravity may change its fees and billing methods at any time effective thirty (30) days after notice of the changes are posted on the Site. All changes will be posted on the Site and you are responsible for reviewing the billing section of the Site to obtain timely notice of such changes. If any such change is unacceptable to you, you may terminate your use of the Membership as provided in Section 8. Your continued use of the Service thirty (30) days after posting of the changes on the Site will mean you accept such change. YOUR ITEM MALL POINTS ARE PAYABLE IN ADVANCE AND ARE NOT REFUNDABLE IN WHOLE OR IN PART. For further information on billing see the Site. If your use of the Service is subject to use or sales tax then Gravity may also charge you for any such taxes, which will be in addition to the rates and charges published in the billing section of the Site. YOU ARE FULLY LIABLE FOR ALL CHARGES UNDER YOUR ACCOUNT, INCLUDING ANY UNAUTHORIZED CHARGES.

(b) Payment by Credit Card. If you pay for the Service by credit card, you represent to Gravity that you are the authorized user of the credit card used to pay Service charges. Each month you use the Service, you agree and reaffirm that Gravity is authorized to charge your credit card. You agree to promptly notify Gravity of any changes to your credit card account number, its expiration date and/or your billing address, and you agree to promptly notify Gravity if your credit card expires or is cancelled for any reason.



7. INDEMNIFICATION

You agree to indemnify, defend and hold harmless Gravity and its subsidiaries and affiliates and their respective directors, officers, shareholders, employees, agents, Service Provider Customers, clients and contractors from and against any loss, claim, demand, cost and expense (including reasonable legal fees) asserted by any third party due or arising from or in connection with your use of or conduct on the Service, your Content, your violation of the Terms of Agreement or your violation of any rights of another User. Gravity reserves the right to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, which shall not excuse your indemnity obligations.



8. TERMINATION

Either you or Gravity may terminate your Account at any time without further obligation to the other. Further, Gravity reserves the right to terminate the Service at any time without further obligation to you. if the service or your account is terminated or cancelled at any time for any reason, you agree to the following: (1) you will not be entitled to any refund or proration of WarpPortal Energy or Game level Item Mall Points (2) you will lose any characters developed, items accumulated or WarpPortal Energy or Game level Item Mall Points purchased and you will not have the right to transfer, sell or assign any characters, items or Item Mall points to anyone else; (3) you may not access the service in any manner or for any reason, including via any other account. in the event that an account is terminated, Gravity may terminate any and all other accounts that share the member name, phone number, email address, internet protocol address Hardware device or credit card number with the terminated account; (4) we may terminate this Agreement (including your Software license and your Account) immediately and without notice if you breach this Agreement or willfully infringe any third party intellectual property rights, or if we are unable to verify or authenticate any information you provide to us, or upon game play, chat or any player activity whatsoever which is, in our sole discretion, inappropriate and/or in violation of the spirit of the Rules of Conduct. If we terminate this Agreement under any circumstances, you will lose access to your Account for the balance of any prepaid period without any refund.



9. PARENTAL GUIDANCE

Parents may find the Site and Service inappropriate for use by persons who are minor under the rules and regulations. While Gravity may choose to monitor and take action upon inappropriate game play, chat or links to the Service, it is possible that at any time there may be language or other material accessible on or through the Service that may be inappropriate for children or offensive to some users of any age. Gravity cannot ensure that other players will not provide Content or access to content that parents or guardians may find inappropriate or that any user may find objectionable. Gravity does not as a matter of policy pre-screen the content of the materials or communications transmitted by each player.



10. INTELLECTUAL PROPERTY

Including but not limited to, all communication features of Gravity contains copyrighted material, trademarks and other proprietary information including, but not limited to, any titles, text, software, photographs, video, graphics, computer code, themes, objects, characters, character names, stories, dialog, catch phrases, locations, concepts, artwork, character inventories, structural or landscape designs, animations, sounds, musical compositions, audio-visual effects, storylines, character likenesses, methods of operation, moral rights, any related documentation, and "applets" incorporated into the WarpPortal, Gateway and the entire contents of Gravity and each area contained therein are copyrighted as a collective work and exclusively owned and licensed by Gravity and protected by the copyright laws of the United States, international copyright treaties and conventions, and other laws. All rights are reserved.

Gravity owns copyrights in the selection, coordination, arrangement and enhancement of such contents. User may not in whole or in part, copy, photocopy, reproduce, translate, reverse engineer, derive source code, modify, disassemble, decompile, or create derivative works based on the Game, modify, publish, transmit, participate in the transfer or sale, create derivative works, or in any way exploit, any of the content contained on Gravity (including, without limitation, content that the Website enables you to download) without the express written permission of Gravity and the copyright owner. In the event of any permitted copying, redistribution or publication of copyrighted material, no changes in or deletion of author attribution, trademark, and legend or copyright notice shall be made. The downloading of copyrighted material from Gravity is allowed by the user expressly for the user's own personal use.

User acknowledges that Gravity and/or third-party content providers remain the owners of all materials posted on Gravity, and that the user does not acquire any of those ownership rights by downloading copyrighted materials.

Failure to comply with the restrictions and limitations shall result in immediate, automatic termination of the Account granted hereunder and may subject you to civil and/or criminal liability. [Notwithstanding the foregoing, you may make one (1) copy of the Game Client and the Manuals for archival purposes only.]

Further exceptions exists for the purpose of fair use and community sharing ideas and community building projects based on Gravity Games including: Original fan creations such as artwork and costumes; Media mix contents showing their in-game play such as, video or descriptions of their play in video Blogs or short stories of their characters adventures; Or musical pieces of the in-game music played, or remixed based on Gravity Interactive's Intellectual Property as long as Credit and links back to the Game Host are given. Using actual Gravity files for the purpose of game creation or selling as your own Intellectual Property is still strictly prohibited.



11. LIMITATION OF LIABILITY

USER ACKNOWLEDGES THAT GRAVITY SHALL NOT ASSUME OR HAVE ANY LIABILITY FOR ANY ACTION BY GRAVITY OR ITS CONTENT PROVIDERS OR OTHER LICENSORS WITH RESPECT TO CONDUCT, COMMUNICATION OR CONTENT OF THE SERVICES. GRAVITY SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE, EXEMPLARY, OR CONSEQUENTIAL DAMAGES (INCLUDING, WITHOUT LIMITATION, LOSS OF BUSINESS PROFITS, BUSINESS INTERRUPTION, LOSS OF BUSINESS INFORMATION OR ANY OTHER PECUNIARY LOSS) IN CONNECTION WITH THE SERVICES OR ANY PRODUCT PROVIDED BY GRAVITY. GRAVITY'S ENTIRE LIABILITY AND USER'S EXCLUSIVE REMEDY WITH RESPECT TO USE OF THE SERVICES AND ALL CONTENTS & SOFTWARE DEVELOPED BY OR FOR GRAVITY SERVICES WHICH IS FOUND TO BE DEFECTIVE USING MEDIA CHOSEN BY GRAVITY SERVICES SHALL BE LIMITED TO AN AMOUNT EQUAL TO THE TOTAL AMOUNT PAID BY USER FOR THE DEFECTIVE SERVICE LESS AN AMOUNT EQUAL TO THE VALUE OF THE SERVICE FOR THE TIME THAT IT OPERATED PROPERLY. GRAVITY'S LIABILITY TO USER FOR ANY AND ALL BREACHES OF THIS AGREEMENT IS LIMITED SOLELY TO THE TOTAL AMOUNT OF WARPPORTAL ENERGY CURRENTLY REMAINING ON THE WARPPORTAL ACCOUNT.

YOU AGREE THAT GRAVITY CANNOT BE HELD RESPONSIBLE OR LIABLE FOR ANYTHING THAT OCCURS OR RESULTS FROM ACCESSING THE SITE OR SERVICE.



12. PRIVACY

Use of our Sites and Service, with or without creation of an Account, are subject to Gravity's Privacy Policy. If you object to your information being used in the way set out in the Privacy Policy, your sole remedy is to cease accessing and using the Sites and Service. We do not guarantee the security of any of your private transmissions against unauthorized or unlawful interception or access by third parties. We can (and you authorize us to) disclose any information about you to private entities, law enforcement agencies, or government officials, as we, in our sole discretion, believe necessary or appropriate to investigate or resolve possible problems or inquiries, or as otherwise required by law. If you request any technical support, you consent to our remote accessing and review of the computer or device you load the Software onto for purposes of support and debugging. You agree that we may communicate with you via email and any similar technology for any purpose relating to the Site, the Service, the Software, and any services or software which may in the future be provided by us or on our behalf.



13. DISCLAIMER OF WARRANTIES

YOU EXPRESSLY AGREE THAT THE SERVICE AND CONTENT ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS AND THAT YOUR USE OF THE SERVICE IS AT YOUR SOLE RISK. GRAVITY AND ALL SERVICE PROVIDER CUSTOMERS EXPRESSLY DISCLAIM ALL WARRANTIES OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT OF INTELLECTUAL PROPERTY OR OTHER VIOLATIONS OF RIGHTS. GRAVITY AND ALL SERVICE PROVIDER CUSTOMERS MAKE NO WARRANTY THAT THE SERVICE WILL MEET YOUR REQUIREMENTS OR THAT THE SERVICE WILL BE UNINTERRUPTED, TIMELY, SECURE OR ERROR-FREE. GRAVITY AND ALL SERVICE PROVIDER CUSTOMERS DO NOT MAKE ANY REPRESENTATION OR WARRANTY AS TO THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SERVICE, THAT THE RESULTS THAT MAY BE OBTAINED FROM SUCH USE WILL BE RELIABLE OR ACCURATE OR THAT THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION OR OTHER MATERIAL PURCHASED OR OBTAINED BY YOU THROUGH THE SERVICE WILL MEET YOUR EXPECTATIONS. GRAVITY MAKES NO WARRANTY THAT DEFECTS IN ITS SOFTWARE WILL BE CORRECTED OR THAT THE WEBSITE OR SERVER THAT MAKES IT AVAILABLE WILL BE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. YOU UNDERSTAND AND AGREE THAT ANY OF THE MATERIAL AND/OR OTHER DATA DOWNLOADED OR OTHERWISE OBTAINED THROUGH THE USE OF SERVICE IS DONE AT YOUR OWN DISCRETION AND RISK AND THAT YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOADING OF SUCH MATERIAL OR DATA. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM GRAVITY OR ANY SERVICE PROVIDER CUSTOMER OR THROUGH THE SERVICE SHALL CREATE ANY WARRANTY NOT EXPRESSLY STATED IN THE TERMS OF AGREEMENT



14. UNACCEPTABLE CONDUCT

Subject to the Terms of Agreements herein, User may not engage in any conduct or communication while using the Services which is unlawful or which restricts or inhibits any other User from using or enjoying the Services. User agrees to use the Services only for lawful purposes. Gravity reserves the right to terminate the User's usership if it determines, in its sole discretion, which the User has engaged in unacceptable conduct. The list of prohibited conduct set forth in Subsections below provides examples of unacceptable conduct, which list is not exhaustive, and Gravity reserves the right, but not the responsibility, to restrict conduct which Gravity deems, in its sole discretion, to be harmful to individual users, damaging to the Services, or in violation of Gravity's or any third party's rights. Gravity may prohibit or delete conduct, communication or content transmitted on Gravity Site or Services that are deemed to be in violation of applicable laws or is harmful to other users, the Gravity Service community, or the rights of Gravity in general. User acknowledges, however, that communication over the Services often occurs in real-time and Gravity cannot, and does not intend to, screen communication in advance.

YOU MAY NOT USE THE SERVICES TO:

A) Use of illegal automated programs, scripts, and computers. The use of any illegal automated program (Ex. 3rd party bot) or system, devices, computers, or scripts on WarpPortal and Gateway is strictly prohibited and may result in criminal liability under the Computer Fraud and Abuse Act, Section 1030 of the United States Code. Violators will be prosecuted to the full extent of applicable law and may also liable for the punitive damage. Gravity may terminate and permanently disqualify any users who, in its sole discretion, determines as being in violation of these Terms of Service. All decisions made by Gravity are final.

B) Harass, threaten or embarrass another User of the Services or to cause distress, unwanted attention or discomfort of such User, or any other person or entity. Gravity does not condone harassment in any form and may suspend or terminate the account of any User who harasses others. Personal attacks, such as those based on a person's race, national origin, ethnicity, religion, gender, lifestyle choice, disablement or other such affiliation, are strictly prohibited.

C) Post or transmit sexually explicit images, or point or reference to such images. Gravity prohibits the transfer or posting of sexually explicit images or other content deemed offensive.

D) Transmit any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, hateful, racially, ethnically or otherwise objectionable content. If User engages in vulgar or abusive language online, even if masked by symbols or other characters, or engages in other impermissible behavior, the User may receive a warning, or be temporarily or permanently excluded from one or more games, bulletin boards, chat areas, or the User's usership may be terminated immediately and the User may be subject to civil liability and/or prosecution by law enforcement authorities.

E) Scroll or carry out any action with a similar disruptive effect. "Scrolling" is defined as repeatedly causing the screen to roll faster than Users are able to type onto it.

F) Impersonate any person, including, but not limited to, Gravity's employees, monitors or hosts. User shall not hold him or her out or portray himself or herself as a Gravity staff user or employee while engaging in all forms of online communication, including, but not limited to, user names, user profiles, voice, text or graphic chat, message postings or any form of communication on line. Impersonation of Gravity staff shall be grounds for immediate account termination.

G) Engage in "disruptive behavior" in chat areas, game areas, bulletin boards, or any other area of the Services. Disruptive behavior shall be deemed to include, but will not be limited to, conduct which purposefully interferes with the normal flow of dialogue in a Service area. Disruptive behavior shall also include, but not be limited to, commercial postings, solicitations and advertisements.

H) Post or transmit chain letters or pyramid marketing schemes. This type of material places an unnecessary load on the Services and is considered a nuisance by many users. Certain types of chain letters and pyramid schemes are also illegal. Such prohibited conduct includes, but is not limited to, the transmission of letters or messages which offer a product or service and which are based on the structure of a chain letter.

I) Posting or transmitting unsolicited advertising, promotional materials, or other forms of solicitation. Gravity Services are not to be used to send unsolicited advertising, promotional material, or other forms of solicitation to other users. User may not use Gravity Services to collect or "harvest" user names without the express permission of those users. Gravity reserves the right to block and/or filter mass email solicitations on or through the service.

J) Violate any operating rule, policy or guideline of any other online service. User further agrees to abide by the rules of the User's Internet service provider.

K) Violate, intentionally or unintentionally, any applicable local, state, national or international law or regulation.

L) Modify any files that Gravity does not specifically authorize User to modify. Use of material, which is subject to the rights of any person or entity without the express permission of such rights holder, is prohibited, and will result in the termination of the User's usership and possible civil and/or criminal liability.

M) Posting too many bulletin boards at once and/or sending multiple unsolicited emails to a single address, sometimes referred to as "spamming," is prohibited. Gravity may take action on a User's account if any of the following offenses is reported: (a) Posting a similar or identical message to more than 5 bulletin boards; (b) Sending unsolicited mail to more than 30 people or (c) Sending more than two (2) unsolicited emails to a single email address. Repeated spamming will result in account termination. In certain situations, the overall pattern of behavior on an account or a set of linked accounts may be determined to be disruptive or abusive, even if no one single act clearly violates any specific policy. In such cases, Gravity reserves the right to determine what patterns of behavior are defined as "high-maintenance" or "disruptive" and may take action against the account(s), ranging from a simple request to moderate the high-maintenance behavior, to total lockout of all linked accounts.

N) Engage in purchasing, selling, or exchanging in-game services, in-game virtual items such as zeny, and item mall through unofficial third party sources for or with real-world money as well as communicating or facilitating any commercial advertisement, solicitation or offer through or within our games pertaining to transactions of this kind except when purchased from Warpportal or otherwise expressly permitted by Warpportal in its sole and absolute discretion.



15. INTERRUPTION OF SERVICE

A) Gravity reserves the right to interrupt the Service from time to time on a regularly scheduled basis or otherwise with or without prior notice in order to perform maintenance.

B) You acknowledge that the Service may be interrupted for reasons beyond the control of Gravity, and Gravity cannot guarantee that you will be able to access the Service or your Account whenever you may wish to do so. Gravity shall not be liable for any interruption of the Service, delay or failure to perform resulting from any causes beyond its reasonable control.



16. GENERAL

The failure of Gravity or the Service Provider Customer to exercise its rights or insist upon the performance of the user's obligation hereunder shall not constitute a waiver or relinquishment of those or any other rights under these Terms of Agreement.

If any provision of the Terms of Agreement is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavor to give effect to the parties intentions as reflected in the provision and the other provisions of the Terms of Agreement shall continue to be binding on and remain in full force and effect.

The Terms of Agreement, together with any separate written or online agreement between you, Gravity and/or the Service Provider Customer (including but not limited to the Mature Content Agreement if applicable to you) constitute the entire and only agreement, and supersedes any prior agreements between you, Gravity and/or the Service Provider Customer, (including, but not limited to all prior versions of the User Agreement, General Terms of Use, and Terms of Agreement, where applicable).

The Terms of Agreement and the relationship between you, Gravity and/or the Service Provider Customer shall be governed by and construed in accordance with the laws of the United States, and such parties agree to submit to the jurisdiction of such courts.

You agree that regardless of any statute or law to the contrary, any action, suit or proceeding arising out of or related to the use of the Service or to the Terms of Agreement must be commenced within 1 year after such claim or cause of action arose or be forever barred.

Section titles in the Terms of Agreement are for convenience only and have no legal or contractual effect or significance.

It is the express wish of the parties that the Terms of Agreement and all related documents have been drawn up in English.



17. NOTICE

Notices may be sent to you or you may send notices to Gravity via either e-mail or regular mail. The Service may also provide notification of any changes to the Terms of Agreement or other matters pertaining to the Service by displaying notices or links to notices generally on the Service.



18. VIOLATIONS

Please report any violations of the Terms of Agreement to our compliance department using the support ticket system section on the official website.



I HAVE READ AND UNDERSTAND THE FOREGOING TERMS OF AGREEMENT AND AGREE TO BE BOUND BY ALL OF ITS TERMS.

Account Policy

1. Purpose of Account Policies

These policies are provided to assist both game & WarpPortal management so everyone can enjoy their stay here. We ask that all users abide by these policies in order to ensure a quality gaming environment and to further improve the game and service. If any changes are made to the policy, a notice on the website will be posted.



2. WarpPortal Online Account Policy

(1) This policy exists to provide consistent support for problematic situations that may occur within the games. Users may be restricted from game/WarpPortal usage if policies are violated.

(2) The user may receive a warning when determined to have committed actions against the policy by the WarpPortal Team [hereafter known as WP Team]. If there is no sign of correcting these actions, service may be limited or suspended on the account. The WP Team may also terminate the usage of the account without notice depending on the severity of the case.

(3) This policy is provided as a guideline in cases in which an identical or similar situation occurs. If it is determined that a better rule may apply, then such action will be adjusted accordingly by the WP Team.

(4) Issues not covered in this policy will follow the End-User License Agreement.



3. User Account Maintenance

Users must maintain their own accounts. No support will be provided for problems that occur due to negligence of the account by the owner. Any attempts to trade items, characters or accounts for real currency will result in a restriction of the accounts without warning. Also, any problems that result from the sharing of an account or other such actions are the sole responsibility of the account owner.



4. Game Policies

Inappropriate Action

The following actions are not allowed in-game or on the WarpPortal forums:

- Using items, skills, or the game environment to intentionally disturb or harass other individuals.
- Repeating a single phrase or similar phrases, preventing others from using the chat effectively.
- Promoting any game, business, website, or organization that is not associated to the WarpPortal.
- Scamming another user to obtain items, currency, or other possessions.
- Using 3rd party programs that have not been approved by the WarpPortal support team.
- Selling or purchasing in-game items or currency from locations other than the WarpPortal website with real-world currency.
- Sharing your account information, or the account information of other users, with other people.
- Using or failing to report an exploit or bug.
- Altering the game client without the permission and instruction of the WarpPortal staff.
- Host or play on an Illegal Private Server.

Inappropriate content

The following content is not allowed to be used in chat, as the name of characters, guilds/clans/factions, parties, or be represented by icons or pictures in-game or on the WarpPortal forums:

- Bypassing the chat filter, or referring to words intentionally blocked by the chat filter.
- Harassing other users using chat, names, icons, or images.
- Referring to, demanding, or promoting sexual or violent acts.
- Releasing or threatening to release the personal information of other users or WarpPortal employees.
- Promoting hatred of a race, ethnic group, nation, religion, political organization or other affiliation.
- Referring to illegal substances or activities, in accordance with United States federal and California State law.
- Impersonation of another user or WarpPortal staff.
- Disclosing bugs, exploit, or instructions on how to accomplish an inappropriate action (see above) to other users.
- Anything giving the impression that a user has special favor or ties to the WarpPortal staff.
- Any disparaging remarks, slander, insults, or rumors involving or pertaining to the WarpPortal, WarpPortal staff, or any affiliated games and companies.

Consequences:

Taking part in any of the above inappropriate actions or using any of the inappropriate content can lead to a number of actions taken. Any of the following are possible actions that may be taken when an account is found involved in an inappropriate activity:

- Warning.
- Temporary game account suspension.
- Removal of items/currency/character levels.
- Revoked forum access.
- WarpPortal account suspension.
- Suspension of associated game accounts (as seen through location, trades, and information).
- Revoked ability to create new game accounts.
- Permanent suspension of game account.
- Permanent suspension of all related game and WarpPortal accounts.

The severity and frequency of ill-mannered actions directly correlates to the severity of the consequence. If you find to have been suspended or denied access in any way, please contact the WarpPortal Support Team to discuss the reason behind the suspension.

*Please note that these rules are a guideline to be followed. These rules may be changed at any time to reflect the growth and changes of both the games and the WarpPortal. The WarpPortal Team reserves the right to deny service to any user we may see as a threat to our company or our games.



Privacy Notice for California Residents

Last revised: December 23, 2019

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who use the Service and reside in the State of California ("consumers" or "you"). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.


Protecting your privacy is important to Gravity Interactive, Inc., and its subsidiaries and affiliates ("Gravity," "we," "our," or "us") because we know how important it is to you. This Privacy Notice describes the information that we collect through websites that we operate (each, a "Site"), our game publisher networks, crowd-sourcing service, and platforms (each, a "Network"), any mobile and web application of ours (each, an "App"), and chat rooms, blogs, web forums, messaging boards, or other public forums in our Apps and Sites (each, a "Forum"); how we use, disclose, and protect your information; and the choices you can make regarding your information. The Sites, Networks, Apps, and Forums are referred to herein, collectively, as the "Service."

1. INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, through your use of the Service, we have collected the following categories of personal information within the last twelve (12) months:


Category Examples Collected
A. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers YES
B. Personal information categories listed in Cal. Civ. Code § 1798.80(e) A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information YES
C. Protected classification characteristics under California or federal law Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) YES
D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies YES
E. Biometric information Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data NO
F. Internet or other electronic network activity information Browsing history, search history, and information on a consumer's interaction with an Internet Web site, application, or advertisement NO
G. Geolocation data Physical location or movements NO
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information NO
I. Professional or employment-related information Current or past job history or performance evaluations NO
J. Non-public education information Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records NO
K. Inferences drawn from any of the information identified above Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes NO

Personal information does not include:

  • Publicly available information from government records;
  • De-identified or aggregated consumer information;
  • Information excluded from CCPA's scope, like personal information protected by other certain sector-specific federal or California statutes.

  • 2. HOW WE COLLECT PERSONAL INFORMATION

    We obtain the categories of personal information listed above from the following categories of sources:

  • Directly From You: The information you provide while using the Service.
  • Indirectly From You: We collect certain technical information, like the Internet Protocol address, when you access and use our Service.
  • Collected and/or Received From Third Parties: We may collect your data from third parties, such as when processing your purchases through our Sites or Apps or when you access our Service through a social networking service ("SNS").
  • Collected Through Mobile Devices: When you use our Apps on your mobile telephone or other mobile device ("Mobile Device"), you are authorizing us to collect, store, use, and/or share, in addition to the information described above, the Mobile Device type; mobile carrier; platform version; navigation, interaction, and engagement information regarding our users; and other information you choose to provide to us. Also, we receive and store information you provide when you sign up to have Short Message Service ("SMS") notifications sent directly to your Mobile Device.

  • 3. HOW WE USE PERSONAL INFORMATION

    We may use the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information;
  • To provide, support, personalize, and develop our products and services for and through our Service;
  • To create, maintain and service accounts;
  • To provide customer service;
  • To process your requests and payments and fulfill orders and transactions;
  • To verify consumer information;
  • To personalize your Site, App, and Forum experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Service and via email or text (with your consent, where required by law);
  • To provide advertising and marketing services;
  • To provide analytic services;
  • To detect and respond to security incidents;
  • To improve our Service;
  • For testing, research, analysis, and product development;
  • For auditing related to a current interaction with the user and concurrent transactions, including but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Gravity's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Gravity about our Service's users is among the assets transfers.

  • Gravity will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

    4. SHARING PERSONAL INFORMATION

    Gravity may disclose your personal information to a third party for a business purpose. When we disclose your personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep your personal information confidential and not use it for any purpose except performing the contract.

    In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

    Category A: Identifiers

    Category B: Personal information categories listed in Cal. Civ. Code § 1798.80(e)

    Category D: Commercial information

    Category F: Internet or other electronic network activity information


    We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates;
  • Our Partners
  • Service providers;
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

  • In the preceding twelve (12) months, we have not sold any personal information.

    5. DATA SECURITY

    We have implemented measures designed to secure and safeguard your personal information from accidental loss and from unauthorized access and disclosure. We maintain physical, electronic, and managerial procedures to limit access to your non-public personal information.

    Unfortunately, transmission of information via the internet is not completely secure. Although we take reasonable precautions to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our Services or other electronic means. Any electronic transmission of personal information is at your own risk.

    6. DATA SECURITY

    The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

    Access to Specific Information and Data Portability Rights

    You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting that personal information;
  • The categories of third parties with whom we share that personal information;
  • The specific pieces of personal information we collected about you (also called a data portability request);
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    o sales, identifying the personal information categories that each category of recipients purchased; and
    o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

  • Deletion Request Rights

    You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

    We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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;
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

  • Exercising Access, Data Portability, and Deletion Rights

    To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at (714) 736-3487
  • Visiting www.warpportal.com
  • Emailing us at caprivacy@gravityus.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;
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

  • 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. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will use only personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

    Response Timing and Format

    We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select 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 without hindrance. 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. NON-DISCRIMINATION

    We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or service;
  • 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, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

    8. CHANGES TO OUR PRIVACY NOTICE

    If you have any questions or comments about this Privacy Notice, the ways in which Gravity collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

    Phone: (714) 736-3487
    Website: www.warpportal.com
    Email: caprivacy@gravityus.com
    Postal Address:
    Gravity Interactive, Inc.
    Attn: Privacy Notice Administrator
    P.O. BOX 2188
    Buena Park, CA 90621

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