Privacy Policy
Last Updated: [2025-4-18]
Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.
Please note that this privacy policy (“Privacy Policy”) only applies to Project EDO (“Game”). If you use any other products or services, please refer to the privacy policy for that particular product or service.
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.
For the purpose of data protection laws, the data controller of your personal information in relation to the Game is Proxima Beta Pte. Ltd.
SUMMARY
Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.
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What information do we need to be able to participate and/or be recruited for the Game? |
· For recruitment for the Closed Beta Test (“CBT”) of the Game, use of the Game Website, and participation within the Game’s CBT, we will collect your personal information as further mentioned in Section 3 (How We Process Your Personal Information below. · To maintain the smooth operation of the Game and to provide the Game to you, we will process the datasets as mentioned in Section 3 ‘How We Process Your Personal Information’. · If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns. |
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How will we use your information? |
· We use your information to (where relevant) set up your account, enable you to use the Game, localise the Game experience, enable interaction between users of the Game, save your progress, ensure the safe and secure operation of the Game, address bugs, optimise and improve the Game, protect users, resolve user queries, and to comply with our legal obligations and enforce our legal rights, etc. · We use your information to facilitate your communications with other players through text chats, and ensure a safe gaming environment. |
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Who do we share your information with? |
· We may use third parties and work with our affiliates to help us deliver the best possible experience (such as surveys). · In some cases, we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information. |
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Where do we process your information?
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· Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. · We have servers for the Game in the United States of America (USA) and Singapore. The servers applicable to your use of the Game will depend upon your location. We also have support, engineering and other teams who may support the Game, including from the USA Singapore. |
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How long do we keep your information? |
· Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Game, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws. · Your information collected during the recruitment phase and use of the Game website will be stored for the lifetime of the Game and deleted 30 days thereafter. |
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How can I exercise my rights over my information? |
· Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data. |
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How will we notify you of changes? |
· Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements. |
We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Game Services. 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 Game for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction).
By children, we mean users under the age of 18 years old. For users located in certain regions, we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.
Other than as provided above, 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 lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.
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Region in which the user is located |
Minimum age of the user |
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Canada |
18 |
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United States |
18 |
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Use |
Legal Basis (where applicable) |
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Information you provide to us (either through a third party or directly) to participate in the Recruitment for the Game and/or during the use of the Game Website |
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Survey Information: Age range, discord id, steam id, email address, game experiences, PC configuration |
We use this information to assess your eligibility to participate in the Game’s CBT1, and to contact you.
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Necessary to perform our contract with you to provide the Game. |
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Website related information: IP address, Android version number, CPU version number (eg. iOS number) |
We use this information for monitoring the performance of the Website and for troubleshooting, such as addressing and remediating technical issues and bugs.
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Necessary to perform our contract with you to provide the Game website. |
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Information you provide to us (either through a third party or directly) to use/access the Game |
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IP Address
Character ID, game account, user nickname, country code, device system version, device brand, device model, device manufacturer, device name, screen resolution, screen orientation, CPU model, GPU information, RAM, Client exports IP, disk memory, network type and buried data reporting
Gameplay statistics (such as player level, in-game performance - combat effectiveness, equipment and online game duration of the user's character in the game, purchased items)
Game data, merit score information, fight performance information, fight matching information, friend interaction information, data analysis data, functional game server log information, knockout report information, fight history related information
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We use this information to:
· Enable you to participate/use the Game, and to detect your location and to provide you with the relevant content specific to your region
· Analyze gameplay behaviour, and to optimize game performance and experience
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Necessary to perform our contract with you to provide the Game. |
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Crashsight SDK: diagnostic logs (user IDs, device identifiers, cpu, storage, network status)
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We use this information for diagnostic and crash reporting, and to assist developer to pinpoint, analyze and resolve abnormal issues (e.g. crashes, latency).
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Necessary to perform our contract with you to provide the Game.
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Perfsight SDK: identity information (open id), device information (Phone memory, GPU information, CPU model, CPU usage rate, Device brand, Network traffic, Device system version, Screen resolution, ROM, RAM, Device manufacturer, CPU architecture, Remaining memory, Device model, System time, UUID, Whether Root, System startup time, Battery status)
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We use this information for client performance monitoring, cloud control (on device level), and for custom data statistical analysis. |
Necessary to perform our contract with you to provide the Game.
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TLog Information: Open ID, Role ID, User Nickname
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We use this information to understand your game behavior to optimize your experience in the Game.
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It is in our legitimate interest to optimize your experience in the Game. |
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Completion Survey Data: Age (non-minors), gender, game experiences, game payment habits (optional), email address
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We use this information to assess your experiences within the Game, and to improve the Game experience. |
Necessary to perform our contract with you to provide the Game.
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Marketing Data: Ad Clickid, media source parameters (eg. campaign name/ adgroup name), player behavior (eg. filling out email/ completing questionnaire)
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We use this information to analyze advertisement effectiveness, and to pass to our advertising partners for optimizing and improving their channels.
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We collect this information with your consent. |
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Data analytics (Facebook):
Contact Information: name,email address, and phone numbers
Event Data: information,
such as site visits, app installations, products purchase information
collected and transferred when people access a website
Hashed Data: including personal data such as email addresses and phone number
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We use this information to monitor the success of our advertising campaigns. |
It is in our legitimate interest to use this information to monitor the effectiveness of our advertisements to provide better Game experience. |
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Data analytics to analyse user acquisition statistics (Google): hashed email address |
We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements. |
It is in our legitimate interest to use this information to monitor the effectiveness of our advertisements so as to provide better gaming experience.
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Communications: Text Communications Data
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We use this information to provide you the Game service, and to analyze your text chat data.
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Necessary to perform our contract with you to provide the Game.
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We have servers for the Game in the United States of America (USA) and Singapore. The servers applicable to your use of the Game will depend upon your location. We also have support, engineering and other teams who may support the Game, including from the USA and Singapore.
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 Game, including providers of services that process information identified in this policy for the purpose of providing the Game, for acquisition purposes and to monitor the effectiveness of our advertisements (eg. Google, Meta, Tik Tok, and Twitter) and for storing of in-game text communications (eg. Unity Software Inc.). 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 Game (i.e., for the purpose(s) described above).
· Companies within our corporate group who process your personal information solely for the purpose of providing the Game to you. All such group companies may only use your personal information in accordance with this Privacy Policy.
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 Game 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.
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Personal Information |
Retention Policy |
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All Personal Data as set out in Section 3 (“How We Process Your Personal Information”), save for the personal data that we collect when you participate in the Game Recruitment/ use of the Game Website
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Stored for the duration of the CBT and deleted 30 days thereafter. You may also request for your data to be deleted at any time and we will do so within 30 days of the request. |
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All Personal data collected when you participate in the Game Recruitment/ use of the Game Website
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Stored for the lifetime of the Game and deleted 30 days thereafter. You may also request for your data to be deleted at any time and we will do so within 30 days of the request. |
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. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, 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 as part of your account by logging into your account.
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 (e.g., account name), as described above in the section “How We Process 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.
Erasure
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 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 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 here or using the contact details set out below, 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 here. 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.
Please get in touch with us if you have any questions. You can reach us in the first instance at this link:
Mailing Address:
International Privacy & Data Protection Centre
30 Raffles Place #18-01
Singapore 048622
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.
SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC
Some jurisdictions’ laws contain additional terms for users of the Game, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.
Canada
If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as set out in Section 8 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.
United States
For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.
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:
We collect and disclose your personal information, including sensitive personal information, for the following purposes:
For additional information about what each type of personal information is used for, see this chart in the main portion of the privacy policy.
We disclose each of the categories of personal information that we collect as described in Section 4 (How We Store and Share Your Personal Information).
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 for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws. In the past 12 months, we may have collected the following types of 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 this chart in the main portion of the Privacy Policy.
Rights under US State Laws:
Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
How to Exercise Your Rights
First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data by contacting us at here. 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 the Data Subject Request Information set out in the section “How We Process Your Personal Information”.
Depending on where you live, 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.
In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.
Questions
If you have questions or concerns regarding this Privacy Policy, please contact us at here.