Privacy Policy

This Privacy Policy explains how we collect, use, share, and protect information when you use our services.

1. About this Privacy Policy

Our Privacy Policy applies to any user of our games platform, related services and websites.

We care about your privacy and we think it is important that you always know what information we obtain about you in the context of your use of the Smilegate website and community and what that information is used for. In the Privacy Policy below, we therefore aim to keep you fully informed as to the type, extent and purpose of the collection, storage, use and processing of personal data on our gaming platform, PC games, mobile game apps, websites, mobile platforms and online communities and/or services relating to the Smilegate online community and related services and software (the "Services") and the Smilegate website on which this Privacy Policy is posted (the "Websites").

Personal data is all information relating to an identified or an identifiable natural person. A person is identified when the identity of a specific person can be deduced from the information itself. A person is identifiable when we can make a connection to a specific person using additional information available to us.

This Privacy Policy applies to the Services and Websites only. You can also see this Privacy Policy at the Websites. We recommend that you read the privacy policy of every other service provider you make use of, in particular before you make your personal data available to them.

Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.

IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT DOWNLOAD, REGISTER WITH, OR USE OUR SERVICES OR VISIT OUR WEBSITES.

By downloading our games, visiting our Websites and using our products and services (including the Services), you acknowledge the terms of this Privacy Policy and the use and disclosure of your personal data as set out in this policy.

If you are using Services in specific countries or regions (for example, when you use services in Republic of Korea), please refer to our Privacy Policy applied in each country.

▶ Korea

2. Who we are

We are a provider of a game platform and related services and applications.

We are Smilegate, Inc., located at 5F, Solid Space Building, 220, Pangyo-ro, Bundang-gu, Seongnam-si, Gyeonggi-do, 13493, Republic of Korea (hereinafter: "SG" "Smilegate" "we" or "us").

We are the provider of the Services and the Websites and the organization responsible for the personal data you provide as part of using the Services and the Websites within the meaning of applicable data protection and privacy laws.

3. How to contact us

You can contact our dedicated privacy contacts with any queries or complaints regarding your data.

If you have any questions about this Privacy Policy or our use of your personal data, if you need to report a problem, or if you would like to exercise one of your rights under this Privacy Policy you can contact us using the following contact details:

Title: Data Protection Officer
Email: privacy_stove@smilegate.com

For the purposes of applicable EU data protection legislation, we also have a representative located within the European Union. The contact details of our EU representative are set out below:

Name: v. KEUSSLER Consulting GbR
Address: v. Keussler Consulting GbR, partnership, Schepp Allee 47, 64295 Darmstadt, Germany
Email: privacy_stove@smilegate.com

4. What information we collect

We collect certain information about you when you use our Services.

We collect the following types of information about you:

  • When you sign up for our Services:
    • with your STOVE account: STOVE ID, Password, Date of birth, (if registering via Gameclub) email, name, security question/answer.
    • with your Facebook, X (formerly Twitter), Apple, Google Play Games, Apple Game Center, LINE, Steam account: Identifier associated with your account.
    • with your Google account: email address.
    • When verifying the parent or legal guardian (“parent”) upon a child’s service registration: email address.
  • When you use our Services or the Websites: service usage records, improper use records, login records, payment records, IP information, country, device information (OS, model name, identifiers such as UUID, advertising identifier), STOVE Nickname, Profile Image.
  • When you contact our customer services: email address and optional PC specifications information.
  • When you pre-register for the game and subscribe to the newsletter: email address or phone number.
  • When you convert your Third-Party account: STOVE ID, Password.
  • When you make a payment: payment records (payment amount, name of product, payment date, order number, etc.).
  • When you win the event: name, phone number, email address, address, Tax identification number (Brazil only), personal identification number, bank name, beneficiary name, account number.
  • When using STOVE Studio: email address, country, representative information, reviewer and settlement representative details, banking information.
  • When applying for the E7WC tournament: date of birth, nationality, name, mobile phone number, email, self-introduction, profile photo, prize payout details.
  • When registering a gaming device: secondary email address, mobile phone number.
  • When using STOVE Creators: email address.
  • When using STOVE Indie Service: developer and company information, application details, and publishing offers.

We may collect additional information for the following customer-related services, and if so, shall enter into a separate agreement with you for the collection and use of personal information: event participation, legal representative's agreement, subscription to channelling services, marketing notifications (Push notification, SMS, email address, etc.).

We log your visits and use of our Services using cookie technology. Some of the information described above is collected automatically, using cookies or mobile cookies (pieces of data sent by a website to your computer and stored on its hard drive or a small file placed on your smartphone). See below for more information about how we use cookies. We also use tracking analysis tools in our Services and Websites that utilize cookies and similar mechanisms.

Where processing is necessary for us to carry out our legal obligations

We have legal obligations that we need to comply with, and we are allowed to collect your personal data when we need to comply with those legal obligations.

IF YOU DO NOT WANT US TO COLLECT ANY OF THE INFORMATION DESCRIBED IN THIS SECTION, DO NOT REGISTER WITH, OR USE OUR SERVICES, OR VISIT OUR WEBSITE.

5. Linking to third party websites

Other websites and applications may use your data differently and have their own privacy policies. You should always read those policies.

Within the Websites or the Services, you may be provided with the option to link through to other websites and services. These other domains, apps and websites are subject to their own privacy practices and we encourage you to read the privacy policies of each and every website and application with which you interact. You visit these other websites or applications at your own risk.

6. Use of our Official STOVE Community

Data you post in the STOVE community may be viewed by others.

As part of our Services, you are able to participate in our official STOVE community. This is publicly available.

You should be aware that personal data that you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online or that you share in an open forum such as the official STOVE community may be viewed and used by others without any restrictions. We are unable to control such uses of your data and by using such services, you assume the risk that the personal data you provide may be viewed and used by third parties for any number of purposes.

7. Why we collect, process and use your information

We use your data to provide you with our Services.

We collect, process and use your personal data for the following purposes:

To provide services and comply with the service contract

  • for the purposes of providing the game platform, online community, our website and associated content and otherwise fulfilling our contract for services.
  • for the purposes of analysing and tracking game data.
  • settling fees, providing content, purchase and fee payments, delivery of goods (prizes from events, etc.).
  • protecting our business and interests, including investigating any potential violation of our Terms and Conditions.

To manage our members and guests

  • to identify our users, confirm users' intent to sign up to the STOVE platform and for age verification purposes.
  • to protect our community from improper or unauthorized use of the Services, Websites and platform.
  • to protect the interests of our users, guests and third parties.
  • to give notifications to our users.
  • to preserve records for disputes mediation.

To deal with complaints

  • to manage and handle complaints, which may include resolving dissatisfaction arising from service use.
  • to provide customer support.

For marketing and promotion purposes

  • to provide services based on demographic information, statistics related to access frequency and the members' use of the service.
  • to notify users about new products, services and events.
  • to develop a better understanding of our customers.
  • to provide tailored services to our users.

8. How long we keep your information for

We don't keep your data forever.

We will not keep your personal data for longer than the term that is necessary for the purposes for which we collect it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation). When it is no longer necessary to retain your data, we will delete the personal data that we hold about you from our systems.

After a request to unsubscribe, we may immediately delete or store your personal data for a maximum of 30 days depending on the individual operational policy of the Game you play, after a request to unsubscribe for the purposes resolving unwanted customer complaints or disputes, etc., such as unwanted deregistration caused by personal data piracy.

If you agree to receive marketing emails, you may withdraw your consent to receive marketing email messages from us by following the unsubscribe instructions provided in our emails. Your email address will be stored until you withdraw your consent.

9. Rights of Users and Parents

Users have various rights in relation to their personal information. These rights may vary depending on the user's location, and parents may exercise those rights on behalf of their child’s personal information processing.

Users may exercise their rights to access (view), correct, delete, suspend processing of, or withdraw consent for the use of their personal information at any time through [Edit Member Information] or [Delete Account] within the service, or by submitting a request via Customer Service (Contact).

You have various rights in relation to the data which we hold about you. To get in touch with us about any of your rights under applicable data protection laws, please use the contact details set out above. We will seek to deal with your request without undue delay, and in any event within any time limits provided for in applicable data protection law. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

In addition, for users located in the EU only, the European General Data Protection Regulation (the "GDPR") gives you the following rights in relation to your personal data:

  • Right to object: This right enables you to object to us processing your personal data where we do so for one of the following reasons:
    • because it is in our legitimate interests to do so;
    • to enable us to perform a task in the public interest or exercise official authority;
    • to send you direct marketing materials;
    • for scientific, historical, research, or statistical purposes.
  • Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.
  • Data Subject Access Requests: You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
  • Right to erasure: You have the right to request that we "erase" your personal data in certain circumstances. Normally, this right exists where:
    • The data are no longer necessary;
    • You have withdrawn your consent to us using your data, and there is no other valid reason for us to continue;
    • The data has been processed unlawfully;
    • It is necessary for the data to be erased in order for us to comply with our obligations under law; or
    • You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
  • Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will notify you before lifting any restriction on processing your personal data.
  • Right to rectification: You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
  • Right of data portability: If you wish, you have the right to transfer your personal data between service providers. In effect, this means that you are able to transfer the details we hold on you to another third party. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you.
  • Right to complain: You also have the right to complain to your applicable data protection authority. Contact details for data protection authorities in the EU are available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Additional Information for Filipino Nationals: The Company ensures that Filipino nationals have the right to file a complaint with the National Privacy Commission in cases where their rights as users have been violated. Contact details for the National Privacy Commission in the Philippines are available at: https://privacy.gov.ph/contactus.

10. Sharing your information

We may share your data with limited third parties (e.g. to help us provide the Services).

In general, your data is processed exclusively by us and we do not pass on any personal user data to third parties unless it is necessary to do so in order to offer you our Services. Where we do share your personal data, we do so with the following categories of recipients:

  • Related entities: We may share your data with certain other entities within the Smilegate group. These entities use your personal data for the purposes of providing their own services (including games) to you. Their use of your personal data is subject to their own privacy policies. For further information on how these Smilegate entities process your personal data, please review those privacy policies.
  • Service Providers: In order to provide the Services we work with certain service providers (e.g. payment service providers, solution providers, customer support service providers) who may, in the course of providing the respective services, receive and process personal data on our instruction and on the basis of a commissioned data processing agreement. In addition, we use certain software tools, including in relation to anti-cheat and fraud prevention analytics, which may allow the software provider to collect certain information for the purposes of providing the relevant services.
  • Regulatory bodies: We may disclose your personal data to data protection regulatory authorities, in response to an enquiry from a government agency, and to other regulatory authorities with jurisdiction over our activities.
  • Professional advisors and auditors: We may disclose your personal data to professional advisors (such as legal advisors and accountants) or auditors for the purpose of providing professional services to us.
  • Replacement providers: In the event that we sell or buy any business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If Smilegate or substantially all of its assets are acquired by a third party, personal data held by us about our clients will be one of the transferred assets.
  • Indicator and tracking analysis tools: We share your personal data with certain entities which provide us with indicator and tracking analysis tools in the services and websites. Other companies that place advertising on our Games or websites may collect information about you when you view or click on advertisements.

In particular, we share your personal data with:

  • Google: We use Google Analytics and AdMob, Ads.
  • Singular: We use Singular's analytics platform.
  • Unity: We use Unity Ads.
  • Facebook: We use Facebook Ads.
  • X (formerly Twitter): We use X (formerly Twitter) Ads.
  • Apple: We use Apple Search Ads.

Please see the "Cookies" section below for further information on the cookies which are used as part of the indicator and tracking analysis tools in the websites.

At your option, in certain circumstances, you have the option of sharing information with others yourself as part of the Games (e.g. if you give out personal data in a publicly accessible player or forum profile). However, we do not transfer such data to other third parties except in special exceptional cases or when obligated by law.

For example, within the Games and the Websites, you may be provided with the option to link through to other websites or STOVE communities. These other domains, apps and websites are subject to their own privacy practices and we encourage you to read the privacy policies of each and every website and application with which you interact. You visit these other websites or applications at your own risk.

You should be aware that personal data that you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your data and by using such services, you assume the risk that the personal data you provide may be viewed and used by third parties for any number of purposes.

Otherwise, your data will only be passed on in special exceptional cases, where we are obligated or entitled to do so by law or upon binding order from a public authority.

11. Changes to this Privacy Policy

Changes to this Privacy Policy apply to your use of our Services after the “effective date.”

We will review this Privacy Policy periodically, and reserve the right to modify and update it at any time. You acknowledge that we may make changes to this Privacy Policy and it is your responsibility to check back to this page from time to time to review the Privacy Policy; provided, however, that if such changes are significant and it is required by applicable laws, we will endeavour to post notice or acquire your consent regarding such significant changes to this Privacy Policy. Changes to this Privacy Policy will come into effect immediately upon such changes being uploaded in the Services or to our Websites.

12. Children's privacy

The Company's Services are intended solely for individuals who are (i) 16 years of age or older in the case of Europe, (ii) 14 years of age or older in the case of South Korea, and (iii) 13 years of age or older in the case of the United States and other countries. However, children may use the Services in the Philippines.

Users who provide their personal information to the Company through the Company's services are deemed to represent that they meet the applicable age requirement.

When collecting children's personal information, the Company may request minimal information from the child, such as the parent's email address, and will process the information with explicit parental consent. If the Company becomes aware that a child's personal information has been collected without parental consent, it will take appropriate measures to delete the information.

If you are a parent and become aware that your child under this age limit has obtained a company account or has otherwise provided personal information to the company, you may use the contact information set forth above to contact the company and exercise rights such as requesting the deletion of your child's personal information and account.

13. Your California privacy rights

If you are located in California, you have certain additional rights.

California Civil Code section 1798.83 permits users who are California residents to request certain information identifying any third party to whom Smilegate may have disclosed, within the past year, personal data pertaining to such user and such user's family for that third party's direct marketing purposes, as well as a description of the personal data disclosed. To request such information, you may contact us using the contact details set out above. Any written inquiry must include "California Privacy Rights Request" in the first line of the description. Please note that we are only required to respond to one request per user each year.

If the California Consumer Privacy Act (CCPA) applies to your information, you can exercise your rights to receive information about our data practices, as well as to request access to and deletion of your information. See the ‘Your rights' section above for more information.

California residents under the age of 18 who are registered users of any online sites, services or applications where this Privacy Policy is posted may under California law request and obtain removal of content or information they have publicly posted. To make such a request, you may contact us using the contact details set out above. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Do Not Track: California law permits our users who are California residents to be informed as to how we respond to web browser "Do Not Track" settings. We do not respond to "Do Not Track" settings at this time.

Do Not Sell or Share My Personal Information: The CCPA provides residents of the State of California the right to opt out of the sale or sharing of their personal information. If you wish to opt out of the sale or sharing of your personal information, you can send an email to privacy_stove@smilegate.com.

Do Not Discriminate: We do not discriminate against our customers by denying services, charging different rates, or providing a different level or quality of goods or services for exercising their rights as outlined in the CCPA.

14. Cookies

We use cookie technology to provide a personalised service to you and for analytics and tracking purposes.

We use cookies (access data files) which save the user's personal information in order to provide a specialized service that is customized and personalized to our users, as well as for analytics and tracking purposes. Cookies are small pieces of data (text files) that are sent by the website server to the user's browser or app and saved on the user's computer and other devices. With respect to its operation, our cookies distinguish between the user's computer or mobile phones but do not differentiate the individual users.

You have a right to choose whether the cookies are installed or not. You may choose to refuse all cookies, confirm each time a cookie is saved, or permit all cookies by going to your browser settings, or by using the Settings or Options function on mobile devices. However, if you refuse all cookies, you cannot use our services that use cookies.

Web browser settings:

  • Chrome: Privacy and security > Clear browsing data
  • Edge: Cookies and site permissions > Manage and delete cookies and site data

Mobile browser settings:

  • Chrome: Privacy and security > Clear browsing data
  • Safari: Advanced > Block all cookies
  • Samsung Internet: Browsing history > Delete browsing history

Google Analytics: The Websites use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help us analyse how users use the Websites. These cookies do not collect any personally identifiable information and are only used for the statistical collection of data such as visits and page hits. Google Analytics' cookies store IP addresses but we cannot link those addresses to any individual or path through the Websites. Google uses the cookies to read information and evaluate visitors' use of the Websites in the form of statistical reports that we can access. The information generated by the cookie about your use of the Websites (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Websites, compiling reports on website activity and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

For further information regarding the way in which Google Analytics uses cookies please see "How Google uses data when you use our partners' sites or apps" at www.google.com/policies/privacy/partners/. You can also stop being tracked by Google Analytics across all websites by going to http://tools.google.com/dlpage/gaoptout.

YouTube API: The Company utilizes the YouTube API Service provided by Google and adheres to the YouTube API Services Terms of Service (https://developers.google.com/youtube/terms/api-services-terms-of-service), YouTube Terms of Service (https://www.youtube.com/t/terms), and Google Privacy Policy (https://www.google.com/policies/privacy). YouTube channel information and content information can be collected via the YouTube API. Users can revoke permission to access their API on the Google Security Settings Page: https://security.google.com/settings/security/permissions.

15. Security

We take security seriously and put in place measures to protect your information.

We have in place appropriate technical and organizational security measures to protect your personal data, including:

  • In order to protect the unauthorized disclosure of users' personal data from hacking or any external break-ins, we use equipment that blocks any external break-ins, which protects the data from any hacking, attacks, or unauthorized access, and we also use encryption, etc., so that personal data may be transferred safely. In particular, the server containing users' personal data is managed separately so that it is not directly linked to the external internet line.
  • In preparation for any unexpected emergencies, we have a policy to back-up the system and data.
  • We are taking protective measures to try and minimize damages caused by computer viruses by using vaccine that are regularly updated.
  • Only the minimum number of people have right of access to the users' personal data.
  • We regularly train our staff who handle personal data on new security technology and personal data protection obligations. Further, through an internal designated personal data protection unit, etc., we try and correct any errors immediately upon detection by checking the company's personal data processing procedure implementation and the relevant personnel's compliance with the personal data protection policies.

16. Where your information is transferred and stored

We may store, transfer and use your data outside your country.

In general, your data will be stored in Japan, Hong kong, where our servers are located. In the event that we transfer your personal data to another country and where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that any such transfers is undertaken in accordance with applicable data protection and privacy laws and that your data is treated securely and in accordance with this Privacy Policy. However, please note that where personal data is stored in another country, it may be accessible to law enforcement agencies in accordance with domestic laws.

Transferee

Details of Transfer

Amazon Web Services, Inc.

  • Basis for overseas transfer: Outsourcing and storage of overseas processing for the performance of a contract
  • Purpose of transfer: AWS cloud server operation and management
  • Items transferred: Section 4, Information Collected, of this Privacy Policy
  • Country, timing, and method of transfer: It is transferred to the AWS Japan region and transmitted over the network at the time of service use.
  • Contact information of the person responsible for information management: aws-korea-privacy@amazon.com
  • Retention and use period of transferred items: It will be retained until termination of the outsourcing agreement or in accordance with the retention periods prescribed by applicable laws and regulations.

Tencent Cloud International Pte. Ltd.

  • Basis for overseas transfer: Outsourcing and storage of overseas processing for the performance of a contract
  • Purpose of transfer: Tencent cloud server operation and management
  • Items transferred: Users’ ID, password, date of birth, email address, name, security questions/answers, and payment information of CrossFire Philippines users
  • Country, timing, and method of transfer: It is transferred to the Tencent Cloud Hong Kong region and over the network at the time of service use.
  • Contact information of the person responsible for information management: cloudlegalnotices@tencent.com
  • Retention and use period of transferred items: It will be retained until termination of the outsourcing agreement or in accordance with the retention periods prescribed by applicable laws and regulations.

17. Legal bases for processing your information

We rely on certain lawful bases to collect, use and share data.

Where you give us your consent to process your personal data

We are allowed to use your personal data where you have specifically consented. In order for your consent to be valid:

  • It has to be given freely, without us putting you under any type of pressure;
  • You have to know what you are consenting to – so we'll make sure we give you enough information;
  • You should only be asked to consent to one thing at a time – we therefore avoid "bundling" consents together so that you don't know exactly what you're agreeing to; and
  • You need to take positive and affirmative action in giving us your consent – for example, we could provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

We currently seek your consent for marketing and advertisement purposes.

Before giving your consent you should make sure that you read any accompanying information provided by us so that you understand exactly what you are consenting to.

You have the right to withdraw your consent at any time, and details can be found in the "Right to withdraw consent" paragraph in the section on your rights above.

Where processing your information is within our legitimate interests

We are allowed to use your personal data where it is in our interests to do so, and those interests aren't outweighed by any potential prejudice to you.

We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to:

  • To handle customer complaints;
  • To verify your identity;
  • To ensure that our systems run smoothly;
  • To protect against improper use or unauthorized use of our Services;
  • To market our Services;

We don't think that any of the activities set out above will prejudice you in any way. However, you do have the right to object to us processing your personal data on this basis. We have set out details regarding how you can go about doing this in the section on your rights above.

Where processing your personal data is necessary for us to carry out our obligations under our contract with you

We are allowed to use your personal data when it is necessary to do so for the performance of our contract with you. For example, we need to process certain personal data about you in order to be able to provide you with related services (including Games branded websites) which you have requested from us and in order to govern the relationship between you and Smilegate.

Where processing is necessary for us to carry out our legal obligations

As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with, and we are allowed to use your personal data when we need to comply with those other legal obligations.

This Privacy Policy should come into effect from Jan. 14, 2026.