Privacy Policy

NGU Inc. (hereinafter referred to as the “Company”) considers users’ personal information important and complies with the Act on Promotion of Information and Communications Network Utilization and Information Protection, etc., and all legal regulations regarding the protection of personal information.

If the company collects, uses or provides the user's personal information, it must notify the user in advance and go through the consent process. If the user does not consent, the company will not collect, use or provide the user's personal information. However, if users refuse consent, their use of all or part of the service may be restricted.

Through the personal information collection/use guide, the company will inform users of the purpose and method of using the personal information provided by the user and that the company is always making efforts to protect the user's personal information.

1. Personal information items collected and collection methods

2. Purpose of collection and use of personal information

3. Retention and use period of personal information

4. Procedures and methods for destroying personal information

5. Provision of personal information

6. Entrustment of collected personal information

7. Rights of minor users and legal representatives

8. Matters concerning the installation, operation, and refusal of automatic personal information collection devices

9. Technical and administrative protection measures for personal information

10. Responding to inquiries regarding personal information

11. Supplementary provisions

12. Personal information items collected and collection methods

The company collects only the information required to provide basic services such as membership registration, smooth response to user inquiries, and provision of various services, as well as information necessary to provide more satisfactory services.

(1) Items of personal information collected

① The company collects the following personal information when first registering as a member or using the game service on the platform below to provide membership, smooth user consultation, and various services. (However, for some games, only login services are provided, and personal information is not collected or stored)

Company game: Required items (ID, nickname, password), optional items (mobile phone number)

Facebook account: Required items (identifier information, ID, profile photo, Facebook friend list), optional items (mobile phone number)

Apple Game Center account: Game Center ID, profile, nickname

Google account: Required items (membership number, Google Plus ID, profile photo, nickname)

Selected item (mobile phone number)

Naver account: Required items (ID, profile photo,), optional items (mobile phone number)

Members can choose whether or not to provide optional items of the above personal information. However, for some services, there may be restrictions on the use of part or all of the service depending on whether or not you enter optional items.

② The following information may be automatically generated and collected during service use or business processing.

• Game service use records, access records and access date and time, download records, payment records, illegal use records, use suspension records, IP addresses, Cookies
• User's mobile phone terminal information (model name, OS version, device identification number, etc.), mobile carrier information, device identification number (UUID), international mobile device identification code (IMEI), Google Advertising ID (Android OS only), terminal language and country information, mobile phone number

③ The company does not collect payment information when using payment methods provided by each mobile carrier or open market operator according to the user's terminal type. However, in some cases, the following information may be requested in order to resolve complaints related to user payment, delivery, account recovery, etc.

④ When it is inevitably necessary for payment, etc. in the process of using free/paid services (recovery and refund, etc.)

Email address, purchase history confirmation, real name, and family relationship proof to confirm payment by someone other than yourself

(2) Personal information collection method

Collected through consent procedure when signing up for the company's service

For promotions and events, collection is conducted through a separate consent process.

Automatically collected through platforms in partnership with the company to provide services

Collected upon request or provided voluntarily by the user when responding to users during payment and use

2. Purpose of collection and use of personal information

(1) The company utilizes the information collected from users for the following purposes.

Securing a smooth communication path for delivering notices and handling complaints, etc.

Providing user services such as handling inquiries regarding the use of paid information and refunding payments

Information on new services, new products, event information, etc.

Other content provision and authentication services (ID/password search, etc.)

(2) Purpose of collection and use of personal information and automatically generated and collected information

Development and specialization of new services or products, provision of services and posting of advertisements according to demographic characteristics, identification of access frequency, statistics on users' service use, record preservation for dispute resolution, handling of civil complaints such as complaint handling, restriction of use by delinquent users, etc.

(3) Purpose of collection and use of information collected when using paid services

Identity verification and payment

(4) Purpose of collection and use of personal information of legal representative

Handling of civil complaints such as confirming consent of legal representative for the collection of personal information of children under 14 years of age, obtaining consent of legal representative when making payments for minors, and addressing user complaints, etc.

3. Retention and use period of personal information

(1) The company will retain and use the user's personal information only during the period when the service is provided, starting from the date of user registration.

Users can request membership withdrawal from the company through the membership withdrawal function, 1:1 customer consultation, phone call, e-mail, etc., and withdrawal is possible after completing the identity verification process. Additionally, if user need to change or modify their personal information, they can request it from the company in writing, through 1:1 customer consultation, by phone, or e-mail.

If the user withdraws from the service provided by the company, withdraws consent to the collection and use of personal information, if the purpose of collection and use has been achieved, or if the retention period has expired, the company will immediately destroy the personal information.

However, if membership withdrawal or the user withdraws consent to the collection and use of personal information, personal information is retained for (7 days) from the date of membership withdrawal or withdrawal, and if this period elapses, the user's personal information will be deleted completely.

(2) In accordance with the relevant Act on Promotion of Information and Communications Network Utilization and Information Protection, etc., and the Enforcement Decree of the same Act, the Company terminates the contract, destroys personal information, etc., to protect the personal information of users who have not used the service for one consecutive year. In this case, the user will be notified of the fact that necessary measures will be taken at least 30 days prior to the date of action, the expiration date of the personal information retention period, and the items of personal information.

(3) Notwithstanding the preceding paragraph, even if the purpose of collection or provision has been achieved, if there is a need to preserve information in accordance with the provisions of laws such as the Commercial Act, or if there is a reason for information protection pursuant to internal policies or other related laws, the company shall comply with the relevant laws and regulations, storing user information for a specified period of time. In this case, the company uses the stored information only for the purpose of storage, and the retention period is as follows.

① Personal information regarding use of the service

Preservation basis: Communications Secrets Protection Act Preservation period: 3 months

② Records of display/advertisement

Basis for preservation: Act on Consumer Protection in Electronic Commerce, etc. Preservation period: 6 months

③ Records of contracts or withdrawals, etc.

Basis for preservation: Act on Consumer Protection in Electronic Commerce, etc. Preservation period: 5 years

④ Records of payment and supply of goods, etc.

Basis for preservation: Act on Consumer Protection in Electronic Commerce, etc. Preservation period: 5 years

⑤ Records of responding to consumer inquiries, claims, or handling disputes

Preservation basis: Act on Consumer Protection in Electronic Commerce, etc. Preservation period: 3 years

⑥ Books and supporting documents for all transactions stipulated by tax laws: 5 years

Reason for preservation: Framework Act on National Taxes

4. Procedures and methods for destroying personal information

As a rule, the company destroys personal information immediately after the purpose of collecting and using it has been achieved.

(1) Order of destruction

The information entered by the user for user registration, etc. is destroyed after being preserved for a certain period of time in accordance with the internal policy and information protection reasons under the law after the purpose of collection and use of personal information has been achieved (Retention of Personal Information in Section 3 and period of use).

(2) Method of destruction

① Personal information preserved in the form of electronic files is deleted using technical methods that render the records unrecoverable.

② Personal information printed on paper is destroyed by shredding or incineration.

5. Provision of personal information

(1) The company uses the user's personal information within the specified scope and does not use it beyond that scope or provide it to a third party without the user's prior consent. However, in the following cases, personal information may be used beyond the specified scope or personal information may be provided to a third party.

① When the company provides personal information to a third party, the company will notify the user in advance of the person who receives personal information, the purpose of using the personal information of the person who receives the personal information, the items of personal information provided, the retention and usage period of personal information of the person who receives the personal information, and obtains the user's consent.

② Personal information is necessary for the performance of a contract regarding the provision of services, and it is significantly difficult to obtain prior consent for economic or technical reasons.

③ When there is an obligation to disclose information under the law, when there is a request from an investigative agency for the purpose of investigation according to the procedures and methods prescribed by law.

(2) To the extent necessary to resolve any issues that arise when users purchase paid items (such as games) on the Platform, the Company may provide users' personal information to the relevant provider of the paid items (such as game development companies), and users agree to such provision.

(3) In the following cases, the company may provide personal information without user consent in accordance with relevant laws.

① When necessary to settle fees for service provision

② When it is necessary for statistical compilation, academic research, or market research and is provided in a form that does not identify a specific individual.

③ In cases where there are special provisions in laws such as the Real Name Financial Transactions and Guarantee of Confidentiality, the Act on Use and Protection of Credit Information, the Framework Act on Telecommunications, the Telecommunications Business Act, the Local Tax Act, the Consumer Protection Act, the Bank of Korea Act, and the Criminal Procedure Act.

6. Entrustment of collected personal information

In order to perform its duties, the company entrusts the handling of personal information to an external professional as follows.

Trustee name:

Entrusted work details: Customer consultation and service operation

Personal information use period: Until membership withdrawal or termination of consignment contract

7. Rights of minor users and legal representatives

Minor users and their legal representatives (refers to persons with parental authority or guardians of minors who have the power of representation in accordance with the provisions of the law without being delegated by the principal, etc.) can inquire, modify, or delete personal information of children under the age of 14 at any time, apply for withdrawal, or withdraw their consent to the collection of personal information.

If a minor user or legal representative applies for correction of personal information, the company will not use or provide the personal information until the correction is completed. In addition, if personal information before correction has already been provided to a third party, the company will notify the third party of the correction without delay so that the correction can be made.

The company will process personal information deleted at the request of a minor user or legal representative in accordance with the provisions of 「3. Retention and Use Period of Personal Information」, and will ensure it is processed in a manner that prevents it from being viewed or used for any other purpose.

Your California Privacy Rights

California Civil Code Section 1798 allows California residents to have the right to request (a) information identifying any third party to whom the company may have disclosed (within the previous calendar year) his/her personal information for that third party’s direct marketing purposes; and (b) a description of the categories of personal information disclosed. If you are a California resident and wish to obtain such information, please send a request email to ngustudio2020@gmail.com

Privacy Rights for California Minors

California residents under the age of 18 having a registered account, have the right to request removal of any content or information that he or she posted anywhere within our Services, such as public forum or message boards in our Websites or Applications. To request removal of such information, you can contact the company at privacy@vespainc.com stating that you reside in California.

8. Matters concerning the installation, operation, and refusal of automatic personal information collection devices

The company uses Cookies to store and retrieve user information in order to provide customized services to users. Cookies are very small text files that the server used to operate the service sends to the user's mobile device/PC and are stored on the user's mobile device/PC. When a user uses the service, the server reads the contents of the Cookies stored on the user's mobile device, verifies the user's information, and provides customized services.

The company uses Cookies to provide customized services, such as linking user profile information, and users have the option to install Cookies. Users can set whether to accept Cookies in their mobile device/PC settings and can also delete Cookies. However, if users do not allow the use of Cookies, they may encounter difficulty in using services that require login.

9. Technical and administrative protection measures for personal information

To ensure safety, the company is implementing the following technical and managerial measures to prevent personal information from being lost, stolen, leaked, altered, or damaged.

(1) Encryption of personal information

Users' personal information is safeguarded by passwords, and important data is protected using security measures such as encrypting files and transmitted data or using the file lock function.

(2) Technical measures against illegal intrusion, etc.

The company continually monitors users' personal information to prevent any leakage or damage caused by hacking or computer viruses. We regularly manage anti-virus programs to prevent any infringement of personal information.

(3) Restrictions on access to personal information processing systems

The company is taking all necessary measures to establish a well-organized database system for processing personal information.

(4) Handling of personal information, training of employees

Employees handling personal information receive regular training from those in charge of acquiring new security technologies and personal information protection obligations.

(5) Management of personal ID and password

In principle, the ID and password used by the user can only be utilized by the user. The company is not responsible for issues arising from the user's personal negligence resulting in the leakage of personal information such as ID and password, or for issues that occur due to basic Internet risks. Please be mindful of your password security, change your password regularly, and exercise caution to prevent your personal information from being leaked when logging in from a public IP.

10. Responding to inquiries regarding personal information

The company appoints a personal information manager to protect users' personal information and address any complaints related to personal information.

Users may inquire about the protection of all personal information that arises while using the company's services from the personal information manager or the department in charge. The company will promptly and adequately respond to user inquiries.

Personal Information Protection Officer

Name: Park Gyeong-min

Department/Position: CEO

Email: ngustudio2020@gmail.com

Personal Information Protection Officer

Name: Park Gyeong-min

Department/Position: CEO

Email: ngustudio2020@gmail.com

If you need consultation regarding other infringements of personal information, please contact the following organizations.

• National Police Agency Cyber Security Bureau: (without area code) 182 (http://cyberbureau.police.go.kr)
• Supreme Prosecutors' Office Cyber Investigation Division: (without area code) 1301 (http://www.spo.go.kr)
• Personal Information Infringement Reporting Center (operated by the Korea Internet & Security Agency): (without area code) 118 (http://privacy.kisa.or.kr)
• Personal Information Dispute Mediation Committee (operated by the Personal Information Protection Committee): 02-2100-2499

11. Supplementary provisions

This privacy policy will be effective from December 1, 2022.

If there are additions, deletions, or modifications to the personal information processing policy due to changes in laws, policies, or security technologies, they will be notified on the company's website, via direct message, email, or mobile service at least 7 days prior to the effective date of the change.