ALARA Prime
Closed Beta Test (“CBT”)
Privacy Policy
Last Updated: 8 July 2022
Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.
Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.
What information do we need to provide for the CBT?
If you register an account to use the CBT then we will need some information from you to set this up. If you choose to set up your profile using a social media account, we also collect information, including name and user ID from that social media account. We will also collect information for analytics purposes, to send you push notifications, and to ensure the security of the CBT. If you need to get in touch with us, we will retain some information so that we can get back in touch with you and address any concerns. More Information.
How will we use your information?
If you participate in the CBT we will use your information to provide the many functions that comprise the CBT. We also use your information for account verification, security purposes and to support and improve the CBT. We do not share your information with any third parties, except where we need to in order to provide the CBT (e.g., use local cloud providers or to back up your data; use our affiliates around the world to help us to deliver the CBT) or monitor the success of our marketing and advertising programs, or where we are instructed to by a court, authority or compelled by law. More Information.
Who do we share your information with?
We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data and support services). When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us deliver the CBT and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.
Where do we process your information?
Our servers are located in Germany and Singapore. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore. More Information.
How long do we keep hold of your information?
We generally retain your information for the period during which you maintain an account for the CBT, after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws. More Information.
How can I exercise my rights over my information?
Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us at dpo@proximabeta.com.
How will we notify you of changes?
Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. More Information.
Data Controller: Proxima Beta Pte. Limited | Email: dpo@proximabeta.com
Representative in the EU for the purpose of EU data protection laws: Tencent International Service Europe B.V. | Email: eudataprotection@tencent.com
Welcome to the ALARA Prime Closed Beta Test!
This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with the ALARA Prime Closed Beta Test and its website (the “CBT”), and sets out your choices and rights in relation to that information. Please read this carefully – it is very important for you to understand how we collect and use your information, and how you can manage it.
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. By continuing to use and submitting your information through the CBT you are acknowledging our rules regarding your personal information as described in this Privacy Policy.
For the purpose of data protection laws, the data controller of your personal information in relation to the CBT is Proxima Beta Pte. Limited (“we”, “us”, “our”). The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore.
Our representative in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V., which is a Dutch company within our corporate group. The registered address of Tencent International Service Europe B.V. is Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands. Our representative in the EU can be contacted at eudataprotection@tencent.com.
Our data protection officer can be contacted at dpo@proximabeta.com. Please reach out to us if you have any questions or concerns regarding the processing of your personal information.
1 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)
- Account registration information: You give us information about you when you set up an account to register for the CBT. If you create and log in via your Steam account, we will receive your User ID, nickname(s), profile picture and user tokens in connection with your Steam account.
- Game data: Relevant information that you provide to us when you set up your account, such as player ID, player display name and player role.
- Location information: We use the information in relation to your location to. We use this information to set up your use of the CBT on a regional server and improve gameplay.
2. Information about you generated as part of the CBT
We automatically collect certain data from you when you take part in the CBT, namely:
- your IP address, Open ID and device information, including device ID, platform and device model) and information regarding your use of the CBT, such as your game behaviour data (e.g. your game role and level, the device you use when playing and related information);
- when you communicate with other users in the CBT (e.g., voice and text chat content and log data);
- general data monitoring data to ascertain how the different SDKs interact and if the ALARA Prime game is working properly;
- crash data to capture and analyse any irregular errors and crashes and improve the functionality of the ALARA Prime game; and
- analytics data to better comprehend the user acquisition process.
2 Cookies
We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the CBT website. 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.
3 Children
Children must not participate in and submit information through the CBT. By children, we mean users under the age of 18 years old.
We do not knowingly collect personal information from children for any purpose. If you believe that we have personal information of a child, please contact us at dpo@proximabeta.com and we will delete such information.
4 How we use your Personal Information
This section describes the different types of personal information we collect from you and how we collect it.
When you participate in and submit information through the CBT, we will in accordance with the law only collect information that is necessary and will not use it for other purposes or services. The specific information collected is as follows:
Personal Information |
Use |
Legal Basis |
Information you provide to us (either directly or through a third party) |
||
Game Data: player ID, player display name, player team, player role, player display name (if set at this stage), role team one, role team two, role team three, player class |
We use this information to create your account for the CBT in accordance with your request. |
Necessary to perform our contract with you to provide the CBT |
Steam Log-in Information: User ID, nickname(s), profile picture, user tokens |
We use this information to create your account for the CBT in accordance with your request. |
Necessary to perform our contract with you to provide the CBT. |
Region Location (manually selected by you) |
We use this information to set up your use of the CBT. We will not store this information once your use of the CBT has been set up. |
Necessary to perform our contract with you to provide the CBT. |
Information generated as part of the CBT |
||
XWID |
We use this ID device to undertake app analytics for debugging and to allow users to use the application as a guest without having to register for an account. |
It is in our legitimate interests to use this information to offer users to use the game without needing to register for an account, and to improve the functionality of the game. |
PGOS data: open ID, player ID, player display name, avatar, IP address |
We use this information to allow you to customize your profile and choose your game names and avatars. |
Necessary to perform our contract with you to provide the CBT. |
Data monitoring data: errorcode , error message, SDK name, SDK version, request URL , response body, sequence ID, stage, log, game ID, client source, session ID, event time, client IP, country, province, city, carrier ID, open ID, event name, OS, OS version, SDK version, network type, bundle ID, app version, login channel ID, device model, device brand, screen width, screen height, CPU name, CPU core, CPU frequency, GPU name, RAM total, ROM total, system language |
We use this information to better understand how various SDKS interact and ascertain if the ALARA Prime game is functioning properly. |
Necessary to perform our contract with you to provide the CBT. |
Text and voice chat data: DT event time, region ID, build ID, platform ID, player ID, player display name, player international open ID, channel ID |
We use this information to facilitate your communications with other users. |
Necessary to perform our contract with you to facilitate the use of the CBT and the posting of your communications with other users. |
Game Data, including: Player information: player ID, player display name, player team, player role, player display name (if set at this stage), role team one, role team two, role team three, player class, App ID, Open ID. Player game behavior data: such as player level, virtual currency, location of the player's choice, phone memory, device brand, device system version, device manufacturer, screen resolution, RAM, system time, device model, device name, App ID, system time, DT event time, Game Map information. Match information: default uplink, target position x, target player ID, target player display name, target player team, target player role, task information, vulnerable wall ID, uplink station ID, adult age confirmed, document EULA accepted version, document PP accepted version, document DTA accepted version, document information, party host player ID, party host display name, party ID, channel ID. Platform information: platform ID, intl status, PGOS status, Steam status. Client performance: avgPing, average FPS, latency, packet loss. Net connect: incoming PPS, outgoing PPS, receive rate, send rate, total In coming Kilobytes, total outgoing Kilobytes. |
We use this information to provide you with the game service and to provide you with feedback and information about your gameplay and progress, to pinpoint those probable important technical issues base on necessary user game logs, to monitor the availability and quality of every game functionalities so that we can take actions if they go wrong, and to use for data analysis so that we can keep optimizing the game operation strategy. |
Necessary to perform our contract with you to provide the CBT. |
Crash Data: login ID, machine ID, memory, CPU, MISC, platform, portable, root directory, seconds of start, time of crash |
This information is used by our third party partner Sentry to solve game crashes and to capture any irregular errors or crashes which users experience whilst using the game, in order to improve the game. |
It is in our legitimate interests to use this information to protect the integrity of the CBT and improve its operation. |
Analytics Data: user agent (e.g. Safari or Chrome or Mozilla or IE), PC UUID, timezone, resolution, IP address, language (and other common information for data reporting), game ID, client source, session ID, event time, client IP, country, province, city, carrier ID, open ID, event name, OS, OS version, SDK version, network type, bundle ID, app version, login channel ID, device model, device brand, screen width, screen height, CPU name, CPU core, CPU frequency, GPU name, RAM total, ROM total, system language |
We use this information to: analyze the user acquisition process, to better understand where all users who downloaded the game originated from (Facebook, Google, Steam, Epic, etc.). |
It is in our legitimate interests to use this information to better provide the CBT to users and to improve its user compatibility. |
5 How We Store and Share Your Personal Information
Your personal information is processed on our servers located in Singapore and Germany. Our web maintenance and operation team, and our technical team, who may access your personal information, are also located in Singapore.
We will follow legal provisions and regulations strictly, and will take strict and secure protective measures to safeguard your rights in accordance with this Privacy Policy.
Only where reasonably necessary will we share your personal information. Situations where this occur are:
- Third parties that provide services in support of the CBT, including Fall Damage Studio, the developer behind the ALARA Prime game, as necessary to further develop and improve the ALARA Prime game, or Sentry which will help locate and solve crash issues. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.
- Companies within our corporate group who process your personal information in order to respond to your enquiries. All related group companies may only use your personal information in accordance with this Privacy Policy.
-
Regulators, judicial authorities and law enforcement agencies, and other third parties for
safety, security, or compliance with the law. There are
circumstances in which we are legally required to disclose information about you to authorities, such as
to comply with a legal obligation or processes, enforce our terms, address issues relating to security
or fraud, or protect our users. These disclosures may be made with or without your consent, and with or
without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or
search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the
legal process. We may seek your consent to disclose information in response to a governmental entity’s
request when that governmental entity has not provided the required subpoena, court order, or search
warrant. We may also disclose your information to:
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
- A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any new owner or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any new owner or other third party involved in such sale or transfer.
6 The 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, although we have implemented and maintained reasonable measures to protect your personal information, the transmission of information via the internet is not completely secure. In the event of a security incident such as a personal data breach, we will initiate an emergency plan to prevent the magnification of the security incident, and will notify you via push notifications, announcements, etc.
7 Data Retention
We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.
Personal Information |
Retention Policy |
Game Data |
Stored for duration of the CBT and deleted three months after completion of the CBT. On specific deletion request, data can be deleted within 30 days. |
Steam Log-in Information |
Login data (including open ID and other information) is stored for duration of the CBT and deleted three months after completion of the CBT. On specific deletion request, data can be deleted within 30 days. Registration data is stored by Steam according to its retention policy. |
XWID |
Stored for duration of the CBT and deleted three months after completion of the CBT. On specific deletion request, data can be deleted within 30 days. |
Data monitoring data |
Stored for duration of the CBT and deleted three months after completion of the CBT. On specific deletion request, data can be deleted within 30 days. |
PGOS data |
Stored for duration of the CBT and deleted three months after completion of the CBT. On specific deletion request, data can be deleted within 15 working days. |
Text and voice chat data |
Stored for duration of the CBT and deleted three months after completion of the CBT. On specific deletion request, data can be deleted within 30 days. |
Player information, player game behavior data, match information, platform information, client performance and net connect |
Stored for duration of the CBT and deleted three months after completion of the CBT. On specific deletion request, data can be deleted within 30 days. |
Crash Data |
Stored for duration of the CBT and deleted three months after completion of the CBT. On specific deletion request, data can be deleted within 30 days. |
Data Analytics |
Stored for duration of the CBT and deleted three months after completion of the CBT. On specific deletion request, data can be deleted within 30 days. |
If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.
8 Your Rights
You have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations). Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at dpo@proximabeta.com.
Access
You 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. If you believe we hold any other personal information about you, please contact us at dpo@proximabeta.com.
Portability
You have the right to receive a copy of certain personal information we process about you. This comprises any 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 Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
Correction
You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any personal information about you that is inaccurate, please contact us at dpo@proximabeta.com.
Erasure
If there is any personal information you believe we process that you would like us to delete or remove, or if you would like to delete your account, please contact us at dpo@proximabeta.com.
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 that has been made available publicly on the CBT 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 have a right to require us to 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). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
Objection
You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at dpo@proximabeta.com.
To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at dpo@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.
9 Announcements
We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the CBT 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.
10 Contact & Complaints
Questions, comments and requests regarding this Privacy Policy are welcome. We have set up a personal data protection team and assigned a designated personal data protection officer. If you have any questions, complaints, or suggestions about this Privacy Policy or data protection-related matters, please contact the data protection officer at 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 region in which you live or work where you think we have infringed data protection laws.
11 Changes
If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.
12 Language
Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.