Welcome to PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE LITE!

This privacy policy explains the when, how and why when it comes to processing of your personal information in connection with the mobile game PLAYERUNKNOWN’S BATTLEGROUNDS MOBILE LITE (“Game”) and the website for the Game (“Website”) (the Game and Website together comprise the “Game Services”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it. Please note that our services are not made available in, or to residents of, the European Union or Switzerland.

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 using the Game Services. By using the Game Services you are accepting our rules regarding your personal information as described in this privacy policy.

In this privacy policy, “we”, “us” or “our” refers to Proxima Beta Pte. Limited, a Singapore-based company. The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore 079903.

Our representative for data protection purposes in Turkey is Özdağıstanli Ekici Avukatlık Ortaklığı, located at Varyap Meridian Grand Tower ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul Turkey, and can be contacted at tencent@iptech-legal.com.

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

The Types of Personal Information We Use

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

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

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

You give us information about you when you register for the Game (your nominated nickname, and information we import from your connected social media account (Facebook, Google and VKontakte) in order to set up your profile, including your name as it appears on your social media profile, your user ID and your profile picture. You also provide us with information when you set up your profile for the Game (including region location and information you elect to provide in order to customise gameplay, such as gender) or your nickname when you log-in as a ‘guest’ in order to use the Game.

You also provide us with information when you participate in a survey in the Game (in which case we will process the information you provide to us as part of the survey, including country, age, gender, profession and email address).

2. Information about you generated as part of the Game (and its in-Game services)

We automatically collect certain data from you when you use the Game Services, namely your IP address and device information (such as application version, battery level, Wi-Fi strength, available space, network type, OS version, platform, carrier, country code, series ID, Android ID, time zone settings, IDFV, device language, screen DPI, device resolution, screen direction, brand, manufacturer, device model, RAM, ROM, CPU info), generated OpenID, registration time, login time and information regarding your use of the Game Services, such as date and time stamps of actions. We also collect and store your data:

each time you interact with us, for example, when you use in-app or in-Game support to communicate with us;
if you choose to log in using a social media service, we import the social media user ID and name of the friends (and in the case of Facebook, their Facebook nickname and profile picture) from your social media profile so that you can connect with your friends;
if you click on a link that advertises the Game, we store the Advertising ID for that advertisement with your profile;
if you enable chat services (audio and/or text and use them whether inside or outside a battle) then we will process such data in order to deliver your messages to other users;
if you conduct any transactions within the Game, we collect information to facilitate your transaction and to maintain transaction records (OpenID, cost, product purchased, IP Address, details of transactions linked to player ID, and device details including OS version, phone model, device root status);
if you contact our support team, we collect information including name (optional), OpenID, device ID, application version, battery level, Wi-Fi strength, free space on device, network type, OS version, browser type, platform, carrier, country code, details of ticket, email address (optional if in-app/in-Game support) and any information that you provide in your communications. You also have the option of providing a photo to illustrate any errors; and
when you are using the Game Services our security feature collects (in addition to the categories of data listed above) device information including the IMEI number and available memory; and a list of installed APK and running apps.

3. Information you generate and display in the course of using the Game Services.

You may provide additional information as part of your profile (such as gender). You may also provide or generate information when you communicate with other users in the Game (chat log data and chat content, both audio and text). We generate an OpenID and use this to store your Game data, and we collect and store your Game play statistics in order to provide you with feedback and information about your Game play and progress. If you participate in a sharing event, we will process your Game data (prop types, wins, ranking and Game play statistics) to prepare a report for you. If you enable push notifications, we collect your Android device token, custom alias name, and IP address.

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“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 functionality.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the Game) or web browser (in the case of the Website) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game Services may be unable to operate as designed.

Children

Our Game Services are not intended for children. Children must not use the Game Services for any purpose. By children, we mean users under the age of 16 years old; or in the case of users located in a country listed in the table below, the relevant age listed for that country.

Country in which the user is located	Minimum age of the user
Russia	18
Egypt	18
Hong Kong	18
India	18
Philippines	18
Turkey	18
Singapore	18

Users who are under the age of 18 are required to obtain parental/guardian consent prior to playing the Game.

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, please contact us at dpo@proximabeta.com and we will delete such information.

How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

Personal Information	Use	Legal Basis (only relevant if you are located in Turkey)
Game
Information you provide to us (either directly or through a third party).
Nickname	We use this information to create your account for the Game in accordance with your request.	Necessary to perform our contract with you to provide the Game.
Social Connect Information (if you choose to log in via your social media account with these networks): Facebook: Name, Facebook ID, profile picture VKontakte: userID, nickname, first name, last name, profile picture Google: User ID, nickname, profile picture	We use this information to: create your account for the Game in accordance with your request; and share in-game photos on Facebook and Vkontakte at your request.	Necessary to perform our contract with you to provide the Game.
Gender (if you elect to provide this information)	We only receive this information if you provide it. It is used in order to customise gameplay.	Necessary to perform our contract with you to provide the Game with gender-specific content in accordance with your request.
Region Location (manually selected by you)	We use this information to: set up your gameplay on a regional server; provide you with your geographic ranking; and improve gameplay.	Necessary to perform our contract with you to provide the Game.
Friends List (Facebook, VKontakte)	If you choose to log-in using a social media service, we import the social media user ID and name of the friends from your social media profile so that you can connect with your friends. If you choose to log-in through Facebook, and connect with your friends that also have the Game, we will import the Facebook nickname and profile picture of those friends.	We collect this information with your consent.
Friends List (manually added by you)	We use this information so that you can connect with your friends.	We collect this information with your consent.
Information generated as part of the Game (and its in-Game services)
Generated OpenID	We generate this and use this to store your Game data (including level and progress) with your profile, and it allows you to connect to the Game server.	Necessary to perform our contract with you to provide the Game.
Game Play Statistics (Level, Score/s), date and time stamps of action	We use this information to provide you with feedback and information about your gameplay and progress.	Necessary to perform our contract with you to provide the Game.
IP Address	We use this information to allow you to connect to the Game server.	Necessary to perform our contract with you to provide the Game.
Device ID, Device Information (application version, battery level, Wi-Fi strength, available space, network type, OS version, platform, carrier, country code, series ID, Android ID, time zone settings, IDFV, device language, screen DPI, device resolution, screen direction, brand, manufacturer, device model, RAM, ROM, CPU info), generated OpenID, registration time, login time	We use this information: to confirm the current network type; to provide users with network type display; to facilitate automatic download of important resources via Wi-Fi; to improve our services, including the functionality of the Game; for security and verification purposes; identify and address bugs and assess game function for optimisation; and to combat users registering for multiple accounts.	It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.
Advertising ID	If you click on a link that advertises the Game, we store the Advertising ID for that advertisement with your profile.	It is in our legitimate interest to use this information to monitor the success of our advertising and marketing programs.
Chat Data (audio and text, whether inside a battle (e.g. during actual gameplay) or outside a battle (e.g. in the game lobby)) and chat log data	If you enable chat services (audio and/or text) then we will process such data in order to deliver your messages to other users.	Necessary to perform our contract with you to provide the chat services in-Game.
Transaction Records: payments on Google Play or iOS App Store (OpenID, cost, product purchased, IP Address, details of transactions linked to player ID, and device details including OS version, phone model, device root status).	We use this information to facilitate your payment and maintain a record of your transaction history.	Necessary to perform our contract with you to facilitate your payment and provide you with details of your transactions.
Customer Support Ticket ID & User Communications with Support: Name (optional), Open ID, device ID, application version, battery level, Wi-Fi strength, free space on device, network type, OS version, browser type, platform, carrier, country code, details of ticket, email address (optional if in-app/in-Game support) and any information that you provide in communications with our support team. You also have the option of providing a photo to illustrate any errors.	We use this information to: improve our services; provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the Game.
Security-Related Information: list of hack or cheating software, in-game screen information, device operation system settings, device information including mobile phone brand, model, CPU structure, CPU model, kernel version, resolution, application package of hack software; IMEI number and available memory; and a list of installed APK and running apps. Security-Related Information (if you are using the game on Game Loop): basic hardware information, operating system information, machine codes for security authentication, identification of malicious files, processes, modules, memory and drivers in connection with game operation.	We use this information: for security and verification purposes, including to detect cheating behaviours; identify and address bugs and assess game function for optimisation; solve game crashes and optimise compatibility of devices with the game; and to combat users registering for multiple accounts.	It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.
Security-related information when transactions are conducted: whether certain billing security features of the Android SDK (security development kit) are installed on the device, and if so the version information.	We use this information when transactions are conducted on your account in order to detect fraudulent payment activity.	It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.
Survey Information: Country, Age, Gender, Profession, Email and content of survey responses.	If you agree to participate in a survey conducted by us, we use this information to improve our services.	We collect this information with your consent.
Sharing Event Report Information: Game data (prop types, wins, ranking and Game play statistics).	If you participate in a sharing event, we use this information to prepare a report for you.	We collect this information with your consent.
Push Notification-related Information: Android device token, custom alias name, and IP address.	If you enable push notifications, we use this information to send you notifications.	Necessary to perform our contract with you to send you notifications about the Game.

We may collect other personal information from you from time to time for specific reasons (such as a promotion in your country). When this happens, we will provide more information on any specific changes to the way we process that personal information that might differ to this privacy policy prior to collecting or processing any additional information. In some cases, that information may be shared with us with your consent – and if that is the case, we will provide you with further information on how we process that information and your rights.

How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide you with the Game Services, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers for the Game Services are located in:

India;
Brazil;
Hong Kong;
Singapore;
Canada; and
the United States.

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams (including the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong and Macau), India and the United States).

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 Services, including providers of cloud services that process information identified in this privacy policy on their servers for the purpose of providing the Game Services (including the sharing of in-game photos on Facebook and Vkontakte), for the purpose of processing customer support ticket IDs and support communication, for the purpose of providing marketing and advertisements and monitoring the success of our marketing and advertising programs and for the purpose of providing payment processing services (including security and fraud detection). All third party service providers are prohibited from using your personal information for any purpose other than providing us with their services.
Companies within the Tencent corporate group who process your personal information in order to operate the Game Services. All related group companies may only use your personal information in accordance with this privacy policy.

Regulators and judicial authorities and law enforcement agencies. There are circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users.
A third party that acquires all or substantially all of us or our business. If we sell or buy any business, undergo a merger, enter into a partnership, or sell some or all of our assets we may disclose your information to the prospective buyer of such business. Under these circumstances, we will always require the prospective buyer to comply with this privacy policy.

Security of Your Personal Information

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

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted through the Game Services or otherwise via the Internet; any transmission is at your own risk.

Data Retentio n

Subject to applicable laws and regulations (including as set out under the “How We Store and Share Your Personal Information” section above), we will only retain your personal information for so long as is necessary to fulfil the purposes as set out under the “How We Use Your Information” section above.

Should your account be terminated by you or us for any reason, we will take steps to ensure that your personal information is no longer available through our services, or otherwise used by us, except where we may be required to retain such personal information under applicable laws and regulations, within a reasonable period of time (subject to technical limitations) after such account termination.

However, it is important to note that communications made by you using our services may put your personal information in the hands of third parties that we cannot control – for example, if you have previously made your personal information public via our services.

Your Rights

Subject to applicable laws and regulations, you may have the right to request to review, receive a copy of and make any corrections to your personal information which we hold, or to request that we cease to collect, process and use or delete any of your personal information that is stored by us and to be provided with information regarding our policies and procedures in relation to processing that information. We aim to respond to all requests made to the Game support under this section. To exercise any of these rights, please contact us using the contact details below.

Please note that we may refuse to comply with a data access request in certain circumstances where an exception exists under local law. When handling a data access or correction request, we will check the identity of the requester to ensure that he/she is the person legally entitled to make the data access or correction request.

Announcements

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

Conta ct & Complaints

We welcome questions, comments and requests regarding this privacy policy. Please address them to dpo@proximabeta.com.

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

Ch anges

If we make any material changes to this privacy policy, we will post the updated policy here. Please check this page frequently to see if there are any updates or changes to this privacy policy.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some countries’ laws contain additional terms for users of the Game Services, which are set out in this section.

If you are a user located in one of the countries below, the terms set out below under the name of your country apply to you.

Bangladesh

Agreement

By accepting this privacy policy, you expressly state that you authorize us to collect, use, store, and process your personal data, including, disclosing to third parties, to the extent provided by this privacy policy. By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to India, Brazil, Hong Kong, Singapore, Canada, the United States and the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong and Macau).

Age Restriction

In order to use the Game, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

Egypt

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. If you do not consent to this Privacy Policy, you must not use the Game.

You are acknowledging your consent to the processing, storage, and cross-border transfer for your personal data. The cross border transfer may occur to any country in which we have databases or affiliates, in particular India, Brazil, Hong Kong, Singapore, Canada, the United States and the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong and Macau).

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal data we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

Sharing of Your Sensitive Personal Information (such as credit card information)

Where we permit any third parties to collect and use your Sensitive Personal Information, we shall take reasonable measures to ensure that the third parties do not further disclose the Sensitive Personal Information.

Opt-Out

You have the right to withdraw your consent in respect of our collection and processing of certain personal information; however, in such an instance, we reserve the right to cease the provision of our services, including all Game Services, to you forthwith.

Age Restrictions

Children under the age of 18 are not allowed to execute online contracts with us or sign up for our services. Parents are required to consent to this privacy policy and indicate that they permit their children under the age of 18 years to avail our services.

Grievance Redressal

Please reach out to our grievance officer at grievanceofficer@proximabeta.com with any questions, complaints or concerns. We will keep you informed of the progress we make in redressing your complaint, and/ or the reasons for delay (if any) in such redressal.

Philippines

Minimum Age

You are at least 18 years of age to be able to use the Game Services.

Changes

We will not implement any material changes to the way we process your personal information, as described in the privacy policy, unless we have notified you and have obtained your consent to such material changes.

Your Rights

You are also entitled to the following rights:

Right to be informed. You have the right to be informed whether personal data pertaining to you shall be, is being, or have been processed, including the existence of automated decision-making and profiling.
Right to object. You shall have the right to object to the processing of your personal data, including processing for direct marketing, automated processing or profiling. When you object or withhold consent, we shall no longer process your personal data, unless the personal data is needed pursuant to a subpoena; the collection and processing are for obvious purposes, including, when it is necessary for the performance of or in relation to a contract or service to which you have bound yourself; or your personal information is being collected and processed as a result of a legal obligation.
Right to access. You have the right to reasonable access to, upon demand, the following:
1. contents of your personal data that were processed;
2. sources from which your personal data were obtained;
3. names and addresses of recipients of your personal data;
4. manner by which such data were processed;
5. reasons for the disclosure of the personal data to recipients, if any;
6. information on automated processes where the data will, or is likely to, be made as the sole basis for any decision that significantly affects or will affect the data subject;
7. date when the personal data concerning you were last accessed and modified; and
8. the designation, name or identity, and address of the personal information controller.

Right to rectification. You have the right to dispute the inaccuracy or error in the personal data and have us correct it immediately and accordingly, unless the request is vexatious or otherwise unreasonable. If the personal data has been corrected, we shall ensure the accessibility of both the new and the retracted information and the simultaneous receipt of the new and the retracted information by the intended recipients thereof. Provided, that recipients or third parties who have previously received such processed personal data shall be informed of its inaccuracy and its rectification, upon your reasonable request.
Right to erasure or blocking. You shall have the right to suspend, withdraw or order the blocking, removal or destruction of your personal data from our filing system.

This right may be exercised upon your discovery and substantial proof of any of the following:

your personal data is incomplete, outdated, false, or unlawfully obtained;
your personal data is being used for purpose not authorized by you;
your personal data is no longer necessary for the purposes for which they were collected;
you withdraw consent or object to the processing, and there is no other legal ground or overriding legitimate interest for the processing;
your personal data concerns private information that is prejudicial to you, unless justified by freedom of speech, of expression, or of the press or otherwise authorized;
the processing is unlawful;
we violated your rights.

Consent

By consenting to this privacy policy, you consent to us:

collecting and processing your personal information as described in the section “How We Use Your Personal Information” above;
sharing your personal data with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as further described in the privacy policy and for the purposes stated therein; and
transferring or storing your personal information in destinations outside the Philippines when the processing shall need to occur outside the Philippines as described in the section “How We Store and Share Your Personal Information” above.

We will also obtain your consent whenever we update or alter information in the privacy policy that is material to your consent above.

Russia

If you are using the Game in Russia, by using the Game Services:

you consent (for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations) to the processing in accordance with this privacy policy of your information; if legitimate interests, optimisation of the Game or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law);
you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular India, Brazil, Hong Kong, Singapore, Canada, the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong and Macau), and the United States;
you consent (for the purposes of Article 152.1 of the Russian Civil Code) with the processing of your image in accordance with this privacy policy; and
you consent, for the purposes of Federal Law “On Marketing/Advertising” that we may share advertising/marketing communications with you, unless you have opted-out from such communications.

We will not implement any material changes to the way we process your personal information, as described in the privacy policy, unless we have notified you. We will notify you of any such material changes and may request you to acknowledge such changes. Unless we require the acknowledgment, you shall be deemed to have agreed to the changes, if you continue using the Game upon the notification.

As regards the representative for Russia, you can contact us at dpo@proximabeta.com. Please include the word “Russia” in the subject line of your email.

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, India, Brazil, Hong Kong, Singapore, Canada, the United States and the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong and Macau).

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at dpo@proximabeta.com.

Turkey

Our Data Controller Representative in Turkey is Özdağıstanli Ekici Avukatlık Ortaklığı for the purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations can be contacted at tencent@iptech-legal.com. Please include the word “Turkey” in the subject line of your email.

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

a) learn whether or not your personal data has been processed;

b) request information about processing if your personal data has been processed;

c) learn the purpose of processing of your personal data and whether your data is being processed in line with that purpose;

d) know the third parties in the country or abroad to whom personal data has been transferred;

e) request rectification in the event personal data is incomplete or inaccurate;

f) request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the Law on Protection of Personal Data (Turkey);

g) object to automatic processing of data, and seek certain remedies in accordance with the Law on Protection of Personal Data (Turkey).

In addition to the above, for cases where we process your personal data based on your explicit consent, you have the right to revoke your consent anytime. Users located in Turkey and under the age of 18 are required to obtain parental/guardian consent prior to participating in the Game Services. Also the above mentioned rights must be used by their parents/guardian on behalf of them.