Welcome to the Honor of Kings Soft Launch!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the Honor of Kings Soft Launch and its website (the “SL”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop participating in the SL. By participating in the SL you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

For the purpose of data protection laws, the data controller of your personal information in relation to the SL is Proxima Beta Pte. Limited (“we”, “us”, “our”). The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore.

Our data protection officer can be contacted at dpo_hok@proximabeta.com.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. You can contact us anytime at dpo_hok@proximabeta.com.

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How We Use Your Personal Information” below.

The following is a high-level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party)

· Information related to account registration, recovery and deletion: You give us information about you when you set up an account to register for the SL. If you create and log in via your social media account, your social media profile picture will be set as your SL profile picture by default. You can elect to change your default profile picture to other options in the SL. We also process certain information about you when you recover your account or delete it.

· Compliance information: To verify your eligibility to participate in the SL.

· Friend information: To allow you to connect with your friends and use SL functions with a social element.

· Customer support and feedback information: Relevant information that you provide to us when you communicate with our customer service, when you give us reviews or feedback or otherwise provide information to us through the SL.

· Survey information: If you choose to participate in a survey about the SL, you may be asked to provide certain personal information, such as your age, gender, email, address, geographic (country) location, device information (phone model and configuration preference), game information (game habits and preferences) and any other content you choose to provide as part of the survey response.

· Promotional activities and events information: If you choose to participate in promotional activities or other events organized by us for the SL, you may be asked to provide certain information, such as your contact information, social media information, payment details and any information required for you to take part in our activities and events.

2. Information about you generated as part of the SL

We automatically collect certain data from you when you participate in the SL, namely:

· your IP address, Open ID, user account identifiers and device information, including device ID, platform and Advertising ID, and information regarding your use of the SL, such as play statistics (e.g. level, heroes, scores, and geographic ranking based on your selected region location);

· each time you interact with us, for example, if you contact our support team;

· when you communicate with other users in the SL (e.g., voice and text chat content and log data);

· if you click on a link that advertises the SL, we store the advertising ID for that advertisement and analytics data (e.g. device data, engagement data and search terms) with your profile;

· if you conduct any transactions within the SL, we collect information to facilitate your transaction and to maintain transaction records (Open ID, cost, product purchased, IP address, device details);

· when you are participating in the SL, our security feature collects (in addition to the categories of data listed above) device information including a list of installed hack software, equipment brand and model, available space on the device, and information about your internet connection including the type;

· when you are using certain features during the SL, such as our mini-forum (e.g. Open ID, profile picture and nickname), our gameplay-related FAQ system (Vlink) or game rooms to play with nearby users (e.g. IP address); and

· for bug fixing and analysis purposes, as well as game speed acceleration and network diagnostics purposes;

· when you play matches without downloading the game, our cloud gaming feature collects your IP address and analytics data.

2. Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Honor of Kings website. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.

For more information about our Cookies policy, click here[IPDP1] .

3. Children

Children must not participate in the SL for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years.

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo_hok@proximabeta.com and we will delete such information.

4. How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. It also identifies the legal basis under which we process your data.

Personal Information		Use	Legal Basis
Information you provide to us (either directly or through a third party)
Account Creation (guest log-in): nickname, guest ID		We use this information to create your account for the SL in accordance with your request and to facilitate your use of SL features.	Necessary to perform our contract with you to provide the SL.
Account recovery: Device information, device ID, log-in chancel, OS type, information on user’s in-game friends, registration information, log data, frequently used heroes, previously used nicknames, gameplay statistics, purchase history, email address and verification codes		We use this information to provide a function for users who have lost their account (e.g. as a result of re-download) to recover account.	Necessary to perform our contract with you to provide the SL.
Account Creation (if you choose to log in via your social media account): · Facebook: Name, Facebook ID, profile picture, user token, OpenID, email address associated with the account · Google Play: User ID, nicknames, profile picture, user token, OpenID, email address associated with the account · Apple: User ID, nicknames, profile picture, user token, OpenID, email address associated with the account · Twitter: User ID, nickname, profile picture, user token, OpenID, email address associated with the account · Discord: User ID, nickname, profile picture, user token, OpenID · VK: User ID, nickname, profile picture, user token, OpenID If you create and log in via your social media account, your social media profile picture will be set as your SL profile picture by default. You can elect to change your default profile picture to other options in the SL.		We use this information to create your account for the SL in accordance with your request and to facilitate your use of SL features. We will use your social media account profile picture as your default profile picture in the SL. If you choose to log in via Facebook, Google Play, Apple or Twitter, we also collect the email address associated with your social media account for account security purposes. If you choose to log in via Discord, you will have to option to link your Discord ID to the game.	Necessary to perform our contract with you to provide the SL. It is in our legitimate interest to ensure enhance account security by collecting the email addresses for log-ins via Facebook, Google Play or Twitter.
Account Creation (if you choose to log in via your Level Infinite account): UID, token, email, password. In addition, we will share information on whether you are under 18, or 18 or older, and your account region information with your Level Infinite account, if you choose to create an Level Infinite account and bind your existing game account to it.		We use this information to create your account for the SL in accordance with your request, to facilitate your use of SL features and to ensure consistency across accounts.	Necessary to perform our contract with you to provide the SL. The sharing of whether you are under 18 or not and your account region information is based on our legitimate interest to ensure compliance and consistent service.
Account Creation (general): Device ID, OpenID, token, and selected country/region at sign-up Regardless of your chosen account creation method, we will process the above data.		We use this information to remember choices (e.g. country/region) you made at sign-up, to improve your experience and to monitor the performance of service during the SL.	It is in our legitimate interest to improve user experience and to monitor service performance.
Account Deletion (in-app): email address, verification codes, region, OpenID, and user token Available via a customer-service interface or through the settings page		We use this information to send verification codes via email, in order to delete your account for the SL in accordance with your request.	Necessary to perform our contract with you to provide the SL.
Compliance Data: OpenID, token, region, user name		We use this information to verify your eligibility to participate in the SL.	It is in our legitimate interest to ensure compliance with applicable age-gating rules.
Friend Information (manually added by you or imported from your social media profile)		We use this information so that you can connect with your friends and use SL functions with a social element.	Necessary to perform our contract with you to provide the SL and connect you with your friends.
Customer Support: name, OpenID, device ID, email address (if contacted via email), details of ticket, complaint and handling, content of correspondence, game data and details of gameplay under review, IP address		We use this information to improve our services and provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the SL.
Survey Information: User and contact information (age, gender, email, address, mobile number, select geographic location (country)), device information (phone model, device configuration preference), game information (game habits and preferences (including recently played games, game duration and favourite game categories and experience, language preference), and other content of survey responses user may choose to provide If you choose to participate in an in-game survey via IMUR, we will only receive an aggregated report of the above data.		We use the survey information to allow you to participate in surveys about the SL to improve the SL.	We collect this information with your consent.
Email (Newsletter)		We use your email to send you our newsletter if you choose to subscribe. You may unsubscribe any time.	We collect this information with your consent
Information you provide to us (either directly or through a third party) to take part in our activities, events or programs We will provide you with additional notice if the information collected for a specific activity, event or program exceeds the scope below.
Promotional activities and events information: If you take part in our promotional activities or events, we will collect information from you to facilitate your participation, such as user ID, contact information, address, payment details, rewards information and gameplay statistics and information. If you need to register an account to take part, we will collect your account registration or log-in information, including your social media information if you choose to log in via third-party social media. Your game account information may also be used to facilitate your participation. Where our activities and events have a social element, we may also collect your friend list (either submitted by your manually or from SL or social media).		We use the promotional activities and events information to allow you to participate in our activities and events.	Necessary to perform our contract with you to allow you to participate in our activities and events.
Content creator program information: If you register to take part in any of our content creator program, we will collect information from you for selection purpose and to facilitate your participation if you are selected, such as your name, user ID, social media information, information relating to your gaming experience, contact information, payment details and your submissions.		We use content creator program information to select participants to join our content creator program, and to allow you to participate in the same if you are selected.	Necessary to perform our contract with you to provide our content creator program.
eSports events and tournaments information: If you take part in Honor of Kings’ eSports events and tournaments, we will collect information from you to facilitate your participation, such as your name, eSports club, contact information, travel or identification documents, nationality, residence information, age information, your game data such as your username, your device information, gameplay statistics and information and information submitted by you to receive prize such as your payment details.		We use eSports events and tournaments information to facilitate your participation in the same. We may need to collect your travel or identification documents for the purposes of verifying your identity to ensure the fairness and security of our eSports events and tournaments. We may also use such information to help arrange accommodation and transportation, if travelling is required for your participation. If your consent is required for the collection of this under application local law, we will seek your consent separately.	Necessary to perform our contract with you to provide eSports events and tournaments. Where we are required under applicable local law to collect the information on the basis of consent, we will seek your consent.
CBT Account Information: Your account information from Honor of Kings’ Closed Beta Test, namely the related OpenID, CBT & SL account registration information and ID.		In order to deliver reward to you for activities that you signed up for during the test.	Necessary to perform our contract with you to deliver rewards.
Information generated as part of the SL
Account Creation & Authentication: IP address, OpenID, system time		We use this information to create your account for the SL in accordance with your request, and authenticate your log in.	Necessary to perform our contract with you to provide the SL.
Game Data: OpenID, IP address (only kept in aggregated format for server improvement), device model, game play statistics (e.g. level, heroes, scores)		We use this information to allow you to participate in the SL and to facilitate your use of SL features.	Necessary to perform our contract with you to provide the SL.
Geographic Matchmaking (optional): GPS information (approximate distance, but no exact location shown)		If you choose to use this feature, we use this information to allow you to connect with users nearby your location. Your and users’ exact location GPS information is not shared with other users.	Necessary to perform our contract with you to allow you to connect with users nearby.
Game room (optional): OpenID, IP address, system time, geographic matchmaking information (if enabled and as described above)		If you choose to use this feature, we use this information to allow you to play with nearby users.	Necessary to perform our contract with you to allow you to connect with users nearby.
Analytics, Crash Reporting & Performance, game speed acceleration and network diagnostics: · User Region: country, province, city, carrier id, region, IP address · Device Information: application version, application ID, battery information, WiFi strength, available space, network type, OS version, OS name, carrier, country code, device language, device resolution, brand, manufacturer, device model, RAM, ROM and CPU information, GPU information, Google advertising ID, Game Frame information, mobile signal strength, network round trip time, network bytes received/sent, login/pay step event information, XWID · OpenID, aggregated IP address, device model, system version information, and base station ID		We use this information to perform general and game data analytics, including for the purposes of track which advertisements have been successful for future campaigns and for payment to advertising partners (such analytics also includes reviewing game performance and payments) and for the purposes of error-fixing, troubleshooting, debugging, game speed acceleration and network diagnostics.	It is in our legitimate interest to carry out data analytics to track which advertisements have been successful for future campaigns and for payment to advertising partners, and for the purposes of solving game crashes, game speed acceleration and network diagnostics.
Push Notifications (Firebase): · Device information: Device model, device name, device manufacturer, running process information · Other: SDK version, application package name, application version, operator name, network type		We use this information to send you push notifications during the SL.	Necessary to perform our contract with you to provide the SL.
Payment Information (Midas in-app purchases - only via Google Play and App store): OpenID, product cost, product purchased, IP address, device information (OS version, phone model, device root status) and details of transactions linked to player ID		We use this information to process your payments as part of the SL.	Necessary to perform our contract with you to process your payments as part of the SL.
Service Information & Connection Management Data: OpenID, device name, device model, login channel ID		We use this information to allow game servers to communicate.	Necessary to perform our contract with you to provide the SL.
Game Update & SDK Data: OpenID, device information (device name and model, login channel ID)		We use this information to detect and download version updates and manage integrated SDKs.	Necessary to perform our contract with you to allow you to play the latest version of the SL and use all functions of the SL.
Text Chat Data		We use this information to facilitate the posting of your communications with other users. We also process text chat data to identify, for example, unsolicited commercial communications, including plug-in sales and advertising, spam, harmful communication, exploits, bullying, harassment, threats of violence or conduct which is hateful, harassing, abusive, racially or ethnically offensive, defamatory, humiliating, threatening, profane or similarly objectionable.	Necessary to perform our contract with you to facilitate the posting of your communications with other users. It is in our legitimate interest to ensure the security and integrity of our service and the safety of our users during the SL.
Voice Chat Data (real-time voice): OpenID, device information (device name, device model, client exports IP, device brand, UUID, system time), SDK version IP address, network type, OpenID, model Please note voice chat contents data is only stored on your device, and is not processed by our servers		We use this information to facilitate the posting of your communications with other users.	Necessary to perform our contract with you to facilitate the posting of your communications with other users.
Voice Chat Data (real time voice for in-game safety): Voice chat data (as described above) are processed and only stored on your device, and is not processed by our servers, except for on receipt of a report or complaint.		We store the last 30 seconds of the voice chat on your device. In case of a report or a complaint we process such voice chat data on our servers to identify, for example, unsolicited commercial communications, including plug-in sales and advertising, spam, harmful communication, exploits, bullying, harassment, threats of violence or conduct which is hateful, harassing, abusive, racially or ethnically offensive, defamatory, humiliating, threatening, profane or similarly objectionable.	It is in our legitimate interest to ensure the security and integrity of our service and the safety of our users during the SL.
Voice Chat Data (non-real time voice messages): OpenID, device information (device name, device model, client exports IP, device brand, UUID, system time), SDK version IP address, network type, OpenID, model, voice file, report data		We use this information to facilitate the posting of your communications with other users.	Necessary to perform our contract with you to facilitate the posting of your communications with other users.
Anti-Cheat Data: Android: OS version, manufacturer, CPU, country code and language, root/simulator status, APK data, process data, SD card cache, APK name and version, start time, SD card target file, host file, screenshots of gameplay (if you are suspected of cheating behaviour), sensor data, critical system library data, Open ID		We use this information to ensure the security of the SL.	It is in our legitimate interest to ensure the security of the SL.
Gift Data: IP address, device model platform data (including device ID, username, token, phone and email), game play statistics, task completion status, game account credits, user gift pack collection record, gift pack distribution status, activity points, identity information (Open ID, role ID), eligibility for gift package distribution, package contents		We use this information to facilitate gift delivery.	Necessary to perform our contract with you to facilitate the distribution of gifts.
Data analytics / profiling (Appsflyer): · Technical information: device identifiers, browser, device, CPU, language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier · Technical identifiers: IP address, user agent; Google Advertising ID, Open ID · Engagement information: ad clicks/impressions, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, URL from the referring website, downloads and installations		We use this information for ad attribution purposes.	It is in our legitimate interest to carry out data analytics and profiling for ad attribution purposes to understand how our users interact with advertisements.
Data analytics / profiling (Firebase): device data (OS, model, app store, app version), device identifiers, event data (session duration, geography, open/launch/update, purchase, country, interests, language, new/established, ad clicks and impressions), analytics data (usage, clearance, crashes, removal, payment)		We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements.	It is in our legitimate interest to allow us to acquire users and to monitor the effectiveness of our advertisements.
Data analytics (Facebook): · Contact Information: email address · Event Data: information shared by the user about people and the actions that they take on the relevant website, app or shop · Device identifiers		We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements. We also use the aggregated and anonymised data for analytics purposes.	It is in our legitimate interest for us to monitor the effectiveness of our campaigns.
Mini-forum: Open ID, profile picture, nickname and likes		We use this information to provide you with the mini-forum for dissemination of official news and information.	Necessary to perform our contract with you to provide the mini-forum.
NetTool: Network information and OS version		We use this information to operate NetTool used to test host reachability.	It is in our legitimate interest to monitor, analyse and fix bugs.
Gameplay-related FAQ system (Vlink):	FAQ and Q&A function: OpenID, RoleID, device information, social platform nickname, and system information, including SDK version, application version, IP address, network type and client language.	We use this information to operate and provide you with our gameplay-related FAQ system.	Necessary to perform our contract with you to provide the gameplay-related FAQ system.
	Data analysis: OpenID, Role ID, device information, social platform nickname, and system information, including SDK version, application version, IP address, network type and client language.	We use this information to operate and provide you with our gameplay-related FAQ system.	It is in our legitimate interest to improve the services we offer.
	Push-notifications: OpenID, RoleID, device information, login channel ID, SDK version, application version, and IP address.	We use this information to operate and provide you with our gameplay-related FAQ system.	Necessary to perform our contract with you to provide the gameplay-related FAQ system.
	System management: OpenID, RoleID, device information, social platform information, and system information, including SDK version, application version, IP address, network type and client language.	We use this information to operate and provide you with our gameplay-related FAQ system.	Necessary to perform our contract with you to provide the gameplay-related FAQ system.
Bug fixing and analysis: Device and user account identifiers and IP address		We use this information to determine which devices commonly encounter bugs and crashes.	It is in our legitimate interest to monitor, analyse and fix bugs.
Cloud Gaming IP Data: IP address		We use this information to enable you to play matches in accordance with your request from a cloud server without downloading the game.	Necessary to perform our contract with you to provide the game from a cloud server without downloading the game.
		We use this information to carry out analytics on the performance and functioning of the game on the cloud server in your city or region, and to improve the functionality of the game on the cloud server.	It is in our legitimate interest to ensure the functioning of, and improve, the game on the cloud server in your city or region.
Cloud Gaming Data Analytics Information (reported to Adjust): Device ID data, user attribution data, web activity data, IP address, user agent		We use this information to carry out data analytics (including operation and maintenance analysis and traffic analysis), to improve the game on the cloud server.	It is in our legitimate interest to use this information to improve the game on the cloud server.

5. How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide you with the SL, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers for the SL are located in Singapore and Brazil.

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore and the People’s Republic of China. Certain personal information processed for data analytics purposes may also be stored and processed by our third-party provider, Adjust, on its servers in Europe.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Third parties that provide services in support of the SL, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the SL, analytics and ad attribution providers, and providers that carry out surveys. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

· Companies within our corporate group who process your personal information in order to operate the SL. All related group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

6. The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted as part of the SL or otherwise via the Internet; any transmission is at your own risk.

7. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
Account Creation, Account recovery (guests only), Account Deletion (in-app), Friend Information, Game Data, Analytics Crash Reporting & Performance, Push Notifications (Firebase), Payment, Information, Data Analytics (Appsflyer, Firebase, Facebook), Geographic Matchmaking, Service Information & Connection Management Data, Game Update & SDK Data, Text Chat Data, Bug Fixing and Analysis Data, Mini-forum, NetTool, Game room, game speed acceleration and network diagnostics, Email (Newsletter)	Stored for the lifetime of your participation in the SL (i.e. until account deletion in accordance with your request) and then for 30 days.
Account Creation (General)	6 months
Compliance Data	1 year after the SL is shut down.
Voice Chat Data (real-time voice) Voice Chat Data (non-real time voice messages)	Real-time voice chat will not be stored. Other information: stored for 1 month. Voice files will be retained for seven days. All other information: 1 month.
Voice Chat Data (real time voice for in-game safety)	Real-time voice chat data will only be stored on your device and not be stored on our servers, unless a report or complaint is made, in which case the last 30 seconds of the data are stored on our servers to enable us to review the complaint or report. This data will be deleted as soon as the review is complete and in any event within 7 days.
Anti-Cheat Data, Gameplay-related FAQ system (Vlink)	90 days or until account deletion in accordance with your request and then for 30 days.
Gift Data	Within 6 months after end of an activity.
Survey information (IMUR)	Any aggregated survey responses collected via IMUR will be retained for one year.
Survey Information (non-IMUR)	If you choose to participate in a survey via a channel other than IMUR, we will retain your survey response for 30 days.
Customer Support information	3 months or within 7 days of a deletion request.
Promotional activities and event information, content creator program information, eSports event and tournament information	For the duration of the activity, event, tournament or program, after which personal information will be deleted within 3 months. For content creator program, if you are not selected after submitting an application to us, we will not store your personal information and will delete it within three months after the selection process has come to an end.
CBT Account Information	For the duration of the activity, after which it will be deleted within 6 months.
Cloud Gaming IP Data	Stored for the duration of the cloud gaming activity.
Cloud Gaming Data Analytics Information	Stored for the duration of the cloud gaming activity by us. Stored for 28 days by Adjust.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

8. Your Rights

This section entitled “Your Rights” applies to users that are located in Brazil.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at dpo_hok@proximabeta.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by contacting us at dpo_hok@proximabeta.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by contacting us at dpo_hok@proximabeta.com.

Erasure

You can delete your account, or remove certain personal information, by contacting us at dpo_hok@proximabeta.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly as part of the SL and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at dpo_hok@proximabeta.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at dpo_hok@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the SL for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Advertising

We will only send marketing messages to you if we have your consent. You may choose to stop receiving marketing messages from us by using the unsubscribe option in the message or contact us at dpo_hok@proximabeta.com.

Consent

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us as set out in Section 9 (Contact). This may affect our provision of the SL to you.

9. Contact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo_hok@proximabeta.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo_hok@proximabeta.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the region in which you live or work where you think we have infringed data protection laws.

10. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

11. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.