Community Privacy Policy
SKPORT is operated by GRYPH FRONTIER PTE.LTD. ("we," "our," or "the Company"), which is the Data Controller under this Privacy Policy (hereinafter referred to as "this Policy"). We value your privacy ("you" or "user") and are committed to protecting your personal data. This Policy outlines how we collect, use, and share information when you use our services. Please note that this Policy applies solely to the SKPORT services provided through our website (www.skport.com) and the related mobile application.Please carefully read and agree to this Policy before using our services, particularly the clauses highlighted in bold. By clicking "Confirm", "Acknowledge", or any other affirmative words, or by starting or continuing to use the services we provide, you acknowledge and agree to the contents of this Policy. If you do not agree with any part of this Policy, you must stop using our services immediately.This Policy informs you about the following:
- 1. Types of personal data we collect.
- 2. How we use your personal data.
- 3. Legal basis for data collection and processing.
- 4. Data sharing.
- 5. Cookies and Similar Technologies.
- 6. Data retention.
- 7. Your rights.
- 8. Age restrictions and children’s protection.
- 9. Data security.
- 10. How to contact us.
- 11. Updates to this Policy.
- 12. Supplementary Privacy Statements for Specific Jurisdictions.
1. Types of Personal Data We Collect
Personal data refers to any information relating to an identified or identifiable natural person, such as name, nickname, interests, contact details, etc. We collect and use your personal data for the purposes outlined in this Policy.
1.1 Data Collected Directly or Obtained from Third Parties
- Account Registration Information: When creating an account, you are required to provide your email address, password, and email verification code.
- Profile Information: You may optionally provide additional information, including nickname, gender, date of birth, personal signature, and profile picture. This helps us provide a personalized and improved service experience.
- Third-Party Social Media Accounts: If you choose to log in via social media accounts (e.g., Google, Apple, Facebook), we may receive your account information from third-party providers based on your authorization.
- Customer Support Information: When you contact our customer support, we may collect your contact information (email, phone number, etc.), as well as any communication records (text, images, audio, video, etc.) to resolve issues or facilitate communication.
- Survey Information: When you participate in surveys, we will collect information you provide, such as name, hobbies, and game playtime, depending on the specific survey content.
- Event Participation Information: If you choose to participate in events (e.g., sweepstakes), we may collect your participation information, such as name, email address, and nickname, based on the event rules.
- Interactive Content: We will collect data that you upload, including images, post content, and follow list information, to enable you to post, edit, and connect with others. We may also use this information for internal analysis. When you interact with other players via text, images, voice, video, or other means, we will collect the interactive content you proactively upload. Please note that the content you post may contain your personal data, so please carefully consider what you disclose.
- Linked Game Information: If the pass account you use to log in to SKPORT is also linked to and registered with game products provided by us or our affiliated companies (hereinafter referred to as "Linked Games"), we will retrieve the corresponding game information of this pass account in the Linked Games (including game account profile, game characters, costumes, infrastructure, real-time game data, and game records) from the Linked Games. This allows you, your friends, or other users to view your game information in the Linked Games within SKPORT.
1.2 Automatically Collected Data
- Device or Software-related Data: To provide the basic functions of our services and ensure the secure and stable operation of the services we provide to you, we will collect your device or software information. This includes configuration information provided by your mobile device, web browser, or other programs used to access our services; your IP address; device model of your terminal device; device identifier or device ID (IMEI/Android ID/IDFA/IDFV/OpenUDID/GUID/OAID/SIM card IMSI information); MAC address; software installation list; device name; device system type and version; browser language settings; device resolution; package name; device settings; hardware and software feature information; system version; App ID; SD card information; network information; WIFI information; and sensor information. If you do not agree to provide the aforementioned information, your user experience may be affected.
- Log Data: This includes logs of login, post logs (upload failure/success, number of uploads, number of draft accesses, upload time), browsing history, search history, interaction records (likes, favorites, follows, comments), private message logs (private message type, sending records, report records, chat click records, profile private message click records), game management logs (game pre-registration, pre-purchase, purchase, participation in tests, viewing, downloading, and installation records), and personalized setting information. This enables you to view your historical records on the client side, and also supports us in operational statistical analysis, customer service complaint handling, and other security analyses to enhance your community experience.
- Network and Security Data: To protect the security of your account and create a fair, healthy, and secure community environment, we will collect your identification information, behavior logs, hardware and operating system information, and process/App or website crash records on our products. This is used to combat behaviors that undermine the fair community environment or interfere with/ disrupt the normal operation of our services, and to better assist you in resolving issues when you report bugs or seek help.
- Cookies and Similar Technologies: Data collected via cookies, scripts, and similar technologies is described in detail in the "Cookies and Similar Technologies" section below.
- Data Shared with Us by Third Parties: This includes: (i) data we receive from third-party applications when you link such applications to our services (e.g., when you log in via third parties such as Facebook, Google, or Apple); and (ii) third-party data used for push notifications, security assurance, and statistical analysis purposes.
1.3 Special Notes
Under specific circumstances, we may collect categories of personal data not listed in this clause, based on your consent or other legal bases. We will provide additional details in accordance with applicable legal requirements regarding any changes to collection or processing methods (if any, that are different from or not explicitly stated in this Policy).
1.4 Sources of Personal Data
We collect personal data from various sources, including other users of our services, our affiliated companies, you/your device, service providers, operating system/platform providers, social networks, business partners, publicly available sources, and data we may infer or generate about users based on other collected data.
2. How We Use Your Personal Data
The personal data we collect is used for the following purposes:
- Assisting you in registering an account, enabling you to manage your account and profile;
- Providing you with the requested services and fulfilling our contractual obligations to you;
- Maintaining network, operational, and account security;
- Developing new products or services and improving user experience;
- Sending you service-related updates, game management notifications, system announcements, and other content;
- Providing personalized recommendations;
- Offering you customer service support;
- Enabling your participation in our surveys and marketing activities;
- Ensuring a harmonious and healthy online environment and preventing malicious content;
- Continuously improving the quality of our services;
- Fulfilling our obligations under applicable laws and regulations;
- Conducting user research, internal research, and analysis;
- Establishing, exercising, or defending legal claims;
- Any other purposes for which we provide specific notice when collecting your personal data.
3. Legal Basis for Data Collection and Processing
Under certain applicable laws, we are required to disclose the legal bases for processing your personal data. These may include:
- Consent: Where we have obtained your consent, which you can withdraw at any time.
- Contractual Necessity: To fulfill our obligations under a service agreement with you.
- Legal Obligation: To comply with legal obligations.
- Legitimate Interests: For purposes such as fraud prevention and security.
- Vital Interests: When necessary to protect someone’s life.
- Public Interest: When required for public tasks or interests.
4. Data Sharing
We prioritize the protection of your personal data and will only share it under legal, legitimate, and necessary circumstances. Your personal data may be shared in the following scenarios:
- 4.1 Other Users: Other users may be able to view the data you display or read the information in posts you create in our community forum services. Additionally, when you post or share content, other users may download or forward it to any other person. The public information you post can be viewed by anyone. We strongly recommend avoiding the sharing of personal data in public posts at all times.
- 4.2 Our Affiliated Companies: We may share your personal data with our affiliated companies for legitimate purposes such as customer support, marketing, or operations. Please be assured that when we share your necessary personal data with our affiliated companies, we will require them to strictly comply with the requirements of this Policy.
- 4.3 Government Authorities: We may provide certain parts of your personal data to government authorities in accordance with applicable laws and regulations or for public interest purposes.
- 4.4 Third-Party Service Providers: We may cooperate with the following types of third-party service providers to help us provide you with services and functions:
- Cloud service providers;
- Data analysis service providers;
- Login and content sharing service providers;
- Advertising service contractors engaged in marketing and advertising campaigns. Their services encompass, but are not limited to, showcasing advertisements tailored to your potential interests and evaluating the efficacy of marketing efforts; and
- Other contractors (if any) for the purpose of providing you with our services.
- 4.5 Mergers, Acquisitions, Restructurings, Bankruptcy, and New Owners: In the event of a merger, acquisition, restructuring, bankruptcy, or other similar events, we will issue an announcement in advance to disclose details of the event and information about the successor entity. We will transfer your personal data to our successor entity in accordance with applicable laws. Additionally, we may transfer your information to third parties under applicable laws:
- If we sell, transfer, merge, or restructure any part 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 potential buyer, new owner, or other third party involved in such business changes; or
- If we or all of our substantial assets are acquired by a third party, in which case the information we hold about you may be sold as part of such assets and transferred to any potential buyer, new owner, or other third party involved in such sale or transfer.
5. Cookies and Similar Technologies
- 5.1 To enhance your user experience and deliver superior services, we and our third-party partners may utilize technologies such as Cookies, scripts, web beacons, Flash Cookies, in-line web links, and local storage to automatically collect information. Our proprietary Cookies and similar technologies serve multiple purposes: streamlining services for your convenience, enabling social media features, and helping us analyze how you interact with our websites. Additionally, certain third-party partners may deploy their own Cookies or comparable technologies on our platforms. The data handling practices of these third-party technologies are governed by their respective privacy policies, not by this Policy. We assume no responsibility for the actions of such third-party Cookies or similar tools.
- 5.2 You have the option to manage or disable Cookies and related technologies through your browser settings or user preferences. However, choosing to restrict these technologies may result in a suboptimal service experience and potentially limit your access to specific features within our services.
6. Data Retention
6.1 Storage Location and Cross-Border Data Transfer
Our servers are located in Singapore. We will store your personal data in accordance with the applicable laws and regulations. You confirm and agree that your personal data may be transferred across borders to countries/regions outside your country/region of your residence. Given our global operations, your personal data may be accessed by our support teams, engineering teams, and/or affiliated companies worldwide. These countries/regions may have different data protection laws from your country/region of residence. We will make reasonable efforts to implement security and compliance safeguards required by applicable laws and regulations.
6.2 Data Transfers outside the EEA and UK
If you are located in the European Economic Area (EEA) or the United Kingdom (UK), when we transfer your personal data to countries/regions outside the EEA and the UK that have been formally recognized by the European Commission as providing adequate protection for personal data, we will process such transfers in accordance with the European Commission’s relevant "adequacy decisions" (if applicable). When transfers are not covered by an adequacy decision, we have implemented appropriate safeguards to ensure that your personal data continues to be protected in accordance with this Policy. The safeguards we adopt include Standard Contractual Clauses (SCCs) issued by the European Commission (including UK Addendum) and/or UK International Data Transfer Agreements (IDTAs) permitted under Article 46 of the UK General Data Protection Regulation (UK GDPR).
6.3 Retention Period
We will retain your data only for the period necessary to achieve the purposes of data collection and processing, or for a longer period as required by applicable laws and regulations. Upon expiration of this period, your personal data will be deleted or anonymized in accordance with applicable laws and regulations.
7. Your Rights
In accordance with applicable data protection legislation, you may have certain data subject rights. You may exercise any of the rights described in this section by using any functionality available within our services and/or sending an email to skport@gryphline.com. We will respond within the statutory time limit, though this period may be extended by an additional two months in certain circumstances. To protect the security of your account and personal data, we may require you to provide additional information to verify your identity before responding to your request. In certain cases, we may, as permitted by applicable laws and regulations, refuse to comply with your request. We may also charge a reasonable fee to comply with your request in accordance with applicable laws.
7.1 Right to Know about Personal Data Collected, Disclosed, or Sold
You have the right to access your personal data we hold about you. including: (i) information on whether your personal data has been collected or disclosed; (ii) the categories of personal data collected or disclosed; (iii) the categories of sources from which personal data is collected; and (iv) the business or commercial purposes of collecting or disclosing personal data (if any). In some jurisdictions, applicable law may entitle you to request copies of the data we hold about you.
7.2 Right to Rectify
If we process your personal data, we will endeavor to implement appropriate measures to ensure your personal data is accurate and up-to-date for which it was collected. If your personal data is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate personal data without undue delay.
7.3 Right to Request Deletion
If the legal basis for processing your personal data (as stated in this Policy) no longer exists, or if other statutory grounds for deletion apply, you have the right to request the deletion of your personal data by sending an email.We provide you with the service of account cancellation. You may delete your account through our product interface, or contact us to exercise your right. We will delete or anonymize all relevant personal data generated by you in a timely manner in accordance with applicable laws and regulations, unless otherwise required by laws and regulations.
7.4 Right to Withdraw Consent
To the extent permitted by applicable laws and regulations, you may withdraw any consent you previously provided to us for specific processing activities, where consent was required to process your personal data.If you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service. Should you withdraw your consent or authorization, we may no longer continue to provide you with the services related to the withdrawal of the consent or authorization, and will no longer process your related personal data. However, your decision to withdraw your consent or authorization will not affect the processing of personal data previously carried out based on your authorization.
7.5 Right to Object
You have the right to object to specific processing of your personal data by us, such as when we process your personal data for direct marketing purposes, or when we process your personal data based on legitimate interests or public interests. If you object to our processing of your personal data based on legitimate interests or public interests, we will cease processing your personal data for that purpose, unless otherwise specifically provided by law. If your personal data is used for direct marketing purposes, you may request us to cease processing your personal data for such direct marketing purposes at any time.
7.6 Right to Restrict Processing
As required by applicable law, you have the right to restrict the processing of your personal data. in particular where:
- You contest the accuracy of your data;
- the processing is unlawful and you oppose the erasure of your data;
- We no longer need your data for the purposes of the processing, but you require the data for the establishment, exercise or defense of legal claims; or
- You have a request to refuse a particular processing and are still awaiting the outcome of our processing.
If you have any of the above requirements, please contact us.
7.7 Right to Opt Out of Marketing
You may exercise this right by clicking the "Unsubscribe" or "Opt Out" link in the marketing communications we send to you.
7.8 Right to Complain to a Data Protection Authority
If you think we have infringed data protection laws, you can lodge a complaint with or report to a supervisory authority within your jurisdiction, or file a lawsuit to a judicial authority within your jurisdiction.
8. Age Restrictions and Children’s Protection
Children (usually considered to be under the age of 18, depending on where you reside) must not use SKPORT for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction). You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.We do not intent to and will not knowingly collect personal data from children without consent from their parents or guardians. We strongly urge parents and guardians to instruct their children never to disclose or give out their personal data when using our services without the prior permission of their parent/guardian. If we learn that we have collected personal data about a child, we will delete that data as quickly as possible. Also, if you believe that we might have any data from or about a child, please contact us.If you are a parent or guardian of a child and are required to provide your email address as part of the verification process, we will process such email address for the purposes of notifying you of changes to processing or this Policy, and for verifying data subject requests from you, in each case in accordance with our legal obligations.
9. Data Security
We will adopt reasonable and feasible security protection measures that meet legal requirements and industry standards to protect your personal data from unauthorized access, disclosure, use, modification, damage, or loss. Depending on the actual situation, the security protection measures we may adopt include: using encryption technologies (e.g., SSL, TLS) to process personal information; anonymizing or de-identifying personal data; establishing systems for data classification and grading, security management, and internal access controls; and conducting internal security and privacy protection training.In the event of a data breach, we will activate the corresponding emergency response plan in accordance with the requirements of laws and regulations, and promptly inform you of the basic facts of the incident, potential impacts, the measures we have taken or will take, suggestions for you to independently prevent and mitigate risks, and remedies for you. We will promptly notify you of relevant details of the incident via email, letter, phone call, push notification, or other means. If it is difficult to notify each individual, we will issue an announcement through reasonable and effective means. At the same time, we will promptly report the handling of the data breach to the relevant authorities in accordance with the requirements of applicable laws and regulations.
10. How to Contact Us
If you have questions about us, this Policy, or how we process your personal data, or have any questions, suggestions, or comments, or if you wish to file a complaint or exercise your data subject rights, please contact us via the following method:Email Address: skport@gryphline.com
11. Updates to this Policy
We may update this Policy from time to time. Any significant changes will be communicated via appropriate channels, such as notifications or email. Continued use of our services after such changes constitutes your acceptance of the updated policy.
12. Supplementary Privacy Statements for Specific Jurisdictions
12.1 Supplemental Statement for California Residents
This section is addressed exclusively to California residents (you). Wherever this section differs from the main body of this Policy, it shall take precedence.
12.1.1 Collection, Use, Sale and Sharing
In the past 12 months, we have collected the categories of personal data from you are detailed in Section 1 of this Policy. We obtain personal data from a variety of sources, as detailed in Section 1.4, “Sources of Personal Data.”We have not processed your sensitive personal information. We do not sell or share the personal data of California residents who are under the age of 16.
12.1.2 Data Retention and Deletion
We shall maintain your data solely for the requisite duration and shall proceed to its deletion in accordance with the stipulated regulations:
- Your data shall be expunged subsequent to the deactivation of your account;
- Upon fulfilling the objectives delineated within this Policy, we shall either erase your data or render it anonymous;
- Notwithstanding, in instances necessitating adherence to statutory minimum retention durations, such as for legitimate purposes encompassing taxation, auditing, fraud prevention, anti-money laundering, or dispute resolution, we shall prioritize these obligations.
12.1.3 Your Rights
Under the CCPA/CPRA, you possess certain rights. In addition to the rights described in this Policy, you can also exercise the following rights by sending an email.
- Right to Opt Out of Sale or Sharing of Personal Information. You may prohibit commercial data sharing (e.g., for personalized ads).
- Right to Limit Use and Disclosure of Sensitive Personal Information. We do not sell or share sensitive data (e.g., biometrics, geolocation). No action needed. We automatically limit sensitive data usage as legally required.
- Right to Non-Discrimination. We will not penalize you for exercising your privacy rights (such as refusing to provide services).
- Shine the Light. You have the right to request information about whether we have shared personal information with third parties for their direct marketing purposes during the preceding calendar year.
- Content Removal for Users Under 18. California residents under 18 years old may request removal of content they personally posted on SKPORT by contacting us. Requests must:
- (a) Clearly identify the content to be removed; and
- (b) Provide sufficient detail to locate the content on our platform.
We only accept these requests via email. Incomplete requests may prevent us from processing your submission. Please note: Removal is not guaranteed to be complete or permanent, as other users may have copied or republished the content.
12.1.4 How to Exercise Your Rights
You can exercise your rights by emailing us. To facilitate the expeditious processing of your request, it is imperative to include in the subject line of the email that you are a resident of California and to delineate your specific request (e.g., data access, data deletion, etc.). Within the body of the email, explicitly articulate your precise requirements (e.g., which data to rectify or remove). To adhere to the stipulations of the CCPA/CPRA and to safeguard each user's information from unauthorized access, we shall undertake verification of your identity prior to the formal processing of your request. We will collect solely the information necessary for identity verification purposes, such as requesting the verification code received by your App account or furnishing historical transaction data.We shall respond to your request within the legally mandated timeframe. Should your request be denied, we will furnish specific reasons for the rejection.
12.1.5 Delegated representative
You may opt to file a request via a delegated representative provided that:
- The delegated representative is an individual or corporate entity registered with the California Secretary of State; and
- You have executed a legitimate written instrument conferring authority upon the representative to act in your stead.
Should you decide to submit a request for the exercise of the right to know or for the deletion of personal information through a delegated representative, in addition to adhering to the aforementioned procedures, please ensure that the representative undertakes the following actions:
- Supply a copy of the signed written instrument that authorizes the delegated representative to act on your behalf;
- Supply any requisite information to authenticate your identity and affirm the delegated representative's entitlement to submit requests on your behalf in accordance with the applicable laws. The information we require to verify your identity will be contingent upon your prior interactions with us and the sensitivity of the personal information in question. Should the delegated representative fail to provide evidence of authorization, we reserve the right to deny the request.