Offline Confidential Testing Survey
Privacy Policy
Last Updated: 26 February 2024
This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with the Delta Force: Hawk Ops Offline Testing Survey (the “Survey”), and sets out your choices and rights in relation to that information. This Privacy Policy only applies to the Survey. If you use any other products or services, please refer to the privacy policy for that particular product or service.
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 responding to the Survey. By responding to the Survey, you are acknowledging how we process your personal information as described in this Privacy Policy.
This Survey has been developed by Proxima Beta Pte. Limited ( "we", "us", "our" ), located at 10 Anson Road, #21-07 International Plaza, Singapore (079903).
For the purpose of data protection laws, we are the data controller of your personal information in relation to the Survey. If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us at dpo_deltaforce@proximabeta.com.
We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Survey. 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.
Children must not use the Survey for any purpose.By children, we mean users under the age of 18 years old.
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, please contact us and we will delete such information.
This section provides more detail on the types of personal information we collect from you, and why.
Personal Information | Use | Legal Basis (where applicable) |
Information you provide to us (either directly or through a third party) | ||
Email address (if you choose to receive game updates) | We use this information to send you games update as per your request. | We use this information with your consent. |
Device information and IP address (collected via Google Analytics) | We use this information to understand our Survey traffic and how visitors use the Survey, for marketing analytics purposes. | It is our legitimate interest to use this information to monitor the performance of, and to improve, our services. |
Survey information (optional): information you provide in response to a survey, which may include age range, country or region of residence, contact information, social media nickname, user game habits and preferences, game feedback and any other information you choose to provide as part of the survey. Please note that surveys are conducted by our third party service provider, IMUR Survey. If you participate in a survey, we will direct you to IMUR Survey and will receive aggregated survey results from IMUR Survey. Please note that IMUR Survey’s Privacy Policy will apply to certain data processed in connection with your participation in the survey. | We use this information to · conduct surveys to better understand our users and develop new services based on survey responses; · determine if you are eligible to participate in game testing events; and · allow you to participate in surveys to further improve our services. | We use this information with your consent. |
We have servers for the Survey in Singapore. We also have support, engineering and other teams who may support the Survey, including from Singapore and the US.
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 Service, including third party providers that carry out surveys, such as IMUR Survey. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., for the purpose(s) describe above).
· Companies within our corporate group who process your personal information solely for the purpose of providing the Survey to you. All such group companies may only use your personal information in accordance with this Privacy Policy.
· Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
· Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
o detect, prevent or otherwise address security, fraud or technical issues; or
o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as 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.
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 through the Survey or otherwise via the Internet; any transmission is at your own risk.
We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.
Personal Information | Retention Policy |
Email address | For as long as you subscribe to games updates. If you submit an un-subscription request, your data will be deleted within 30 days. |
IP address | Stored for 30 days and removed within 30 days thereafter. |
Survey information | Stored for 30 days by IMUR Survey and removed thereafter, unless you request deletion at an earlier time. |
Some jurisdictions’ laws grant specific rights to users of the Survey. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.
You may have certain rights in relation to the personal information we hold about you. To exercise your rights, please contact us.
Access
You may 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 to us by contacting us at dpo_deltaforce@proximabeta.com.
Portability
You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g. survey information) or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.
Correction
You may have the right to correct personal information we hold that is inaccurate. If you believe we hold any personal information about you and that information is inaccurate, please contact us.
Erasure
You may have the right to request that we delete personal information we hold about you by contacting us at dpo mailbox. 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.
Restriction of Processing to Storage Only
You may have a right to require that we 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). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
Objection
You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at dpo_deltaforce@proximabeta.com, and we will consider your request.
Consent Withdrawal
To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at dpo_deltaforce@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. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.
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 Survey for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.
Advertising and marketing
You can choose to stop receiving personalised advertising or marketing promotions from us by following the unsubscribe instructions included in our emails or by contacting us at dpo_deltaforce@proximabeta.com.
Please get in touch with us if you have any questions. You can reach us in the first instance at:
Email: dpo_deltaforce@proximabeta.com
We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.
If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.
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.
SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC
California
This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”) (as amended by the California Privacy Rights Act of 2020) (“CCPA”). For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the CCPA and do not include information excluded from the CCPA’s scope.
Collection and Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information from or about you or your device:
· Identifiers, such as your email address, IP address. This information is collected directly from you if you choose to sign up for game updates.
· Geolocation data such as your region location provided as part of your survey responses. This information is collected directly from you.
· Information you provide as part of your survey responses (collected via IMUR Survey). This information is collected directly from you.
· Other information described in subdivision (e) of Section 1798.80, including information about your gender, nationality, or age. This information is collected directly from you in the context of being our consumer.
We collect and disclose your personal information for the following purposes:
· To provide you with the Survey.
· To provide you with game updates if you sign up for such updates.
· To monitor the performance of, and to improve, our services.
· To allow you to participate in survey and assess your eligibility for game testing event, to further improve our services and develop new services based on survey responses.
For additional information about what each type of personal information is used for, see Section 3 (How We Process Your Personal Information).
We disclose each of the categories of personal information that we collect to the following types of entities:
· Other companies within our corporate group who process your personal information in order to operate the Survey.
· Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
· Regulators, judicial authorities and law enforcement agencies
· Entities that acquire all or substantially all of our business.
In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “Share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.
In addition, we do not use or disclose sensitive personal information about you.
Retention of Your Personal Information
The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see Section 6 (Data Retention).
Rights under the CCPA:
If you are a California resident and the CCPA does not recognize an exception that applies to you or your personal information, you have the right to:
· Request we disclose to you free of charge the following information covering the 12 months preceding your request:
o the categories of personal information about you that we collected;
o the categories of sources from which the personal information was collected;
o the purpose for collecting personal information about you;
o the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
o the specific pieces of personal information we collected about you;
· Request we delete personal information we collected from you, unless CCPA recognises an exception;
· Request we correct inaccurate personal information that we maintain about you; and
· Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.
We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
How to Exercise Your Rights
If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 8 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need you to provide certain information such as your region location, email address, or any other information necessary to verify your identy.
Under the CCPA, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.
Questions
If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 8 (Contact).