Last Sentinel Game Website Privacy Policy

Last Updated: December 7, 2023

Thank you for using the website for Last Sentinel! 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 the website (the “Website”) for the game Last Sentinel (“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 (LINK) here.

For the purpose of data protection laws, the data controller of your personal information in relation
to the Website is Proxima Beta Pte. Limited.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by
clicking ‘More Information’.

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

What information do we collect from you? If you sign up to receive our newsletters, we will collect your email address and geolocation to send you our newsletters which contains news and updates about the Game. 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. More information (LINK)
How will we use your information? We use your information to provide you with news and updates to the Game, to understand how visitors use the Website, and to comply with our legal obligations and enforce our legal rights. More information (LINK)
Who do we share your information with? We use third parties and work with our affiliates to help us deliver the best possible experience. 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 Website (i.e., to fulfil the purpose(s) described above). 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. More information (LINK)
Where do we process your information? 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 Website in the United States. The servers applicable to your use of the Website will depend upon your location. We also have support, engineering and other teams who may support the Website. For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent first or taking into account adequacy assessments. More information (LINK)
How long do we keep your information? Unless otherwise required or permissible by applicable laws, we retain your information 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. More Information (LINK)
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. More information (LINK)
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. More Information (LINK)

Welcome to the Last Sentinel website!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the website (the “Website”) for the game Last Sentinel (the “Game”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Website. If you use any other products or services please refer to the privacy policy for that particular product or service.

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 Website. By using the Website you are acknowledging how we process 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 Website is Proxima Beta Pte. Limited (“we”, “us”, “our”). 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 (LINK)here. You can also reach out to our data protection officer at dpo_lastsentinel@levelinfinite.com. We have representatives for data protection purposes listed (LINK) here.

  1. Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the 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 (LINK) here.

  1. Children

Children must not use the Website 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; or in the case of a region where the minimum age for processing personal information differs, such different age. 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.

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 (LINK) contact us.

Region in which the user is located Minimum age of the user
European Ecenomic Area 16
Switzerland 16
United Kingdom 13
United States 13
  1. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in Brazil, the European Economic Area, Indonesia, Switzerland, Thailand, Türkiye or the United Kingdom, it also identifies the legal basis under which we process your data.

Personal Information Use Legal Basis
Email address and geolocation We use this information to send you our newsletter, which contains news and updates about the game We use this information with your consent.
Engagement Information: time of sign up. We sue this information to perform statistics on user engagement on the Website and for monitoring the performance of the Website. It is in our legitimate interests to use this information to monitor users' engagement on, and performance of, the website.

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

  1. How We Store and Share Your Personal Information

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 Website in the United States. The servers applicable to your use of the Website will depend upon your location. We also have support, engineering and other teams who may support the Website.

For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent first or taking into account adequacy assessments.

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 Website, including providers of services that process information identified in this policy for the purpose of providing the Website. 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 Website (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 Website to you. All such group companies may only use your personal information in accordance with this Privacy Policy.
  • Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
  • Third parties to ensure safety, security, or compliance with laws. We may 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 (such as 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 prospective buyer, 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 prospective buyer, new owner, or other third party involved in such sale or transfer.
  1. The Security of Your Personal Information

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 Website or otherwise via the Internet; any transmission is at your own risk.

  1. Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above (see section: 3) 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.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal information Retention Policy
Email address and geolocation Stored for as long as you subscribe to news and updates about the Game. If you submit an un-subscription request, your data will be deleted within 30 days.
Engagement Information: time of sign up. Stored for as long as you subscribe to news and updates about the Game. If you submit an un-subscription request, your data will be deleted within 30 days.
  1. Your Rights

Some jurisdictions' laws grant specific rights to the users of the Website. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to a 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. To exercise your rights, please (LINK) 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 to us by contacting us at dpo_lastsentinel@levelinfinite.com.

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 or pursuant to our contract with you, as described above in the section “How We Use 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. If you believe we hold any personal information about you and that information is inaccurate, please (LINK)contact us.

Erasure
You may have the right to request that we delete personal information we hold about you, by contacting us at dpo_lastsentinel@levelinfinite.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.

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 dpo_lastsentinel@levelinfinite.com, 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 dpo_lastsentinel@levelinfinite.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. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

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 Website for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.

  1. Contact

Please get in touch with us if you have any questions You can reach us in the first instance at:

Email: dpo_lastsentinel@levelinfinite.com

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.

  1. Changes

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.

  1. 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.

Our Representatives in Certain Jurisdictions

Jurisdiction Representative Address Contact Details
EU Proxima Beta Europe B.V. Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands
dpo_lastsentinel@levelinfinite.com
UK Image Frame Investment (UK) Limited Suite 1, 4th Floor 80 Strand, London, United Kingdom WC2R 0RL dpo_lastsentinel@levelinfinite.com

SUPPLEMENTAL TERMS - JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Website, 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.

France
Instructions for the processing of your personal data after your death. You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us as set out in Section 8 (Contact).

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, including sensitive personal information (denoted by ), from or about you or your device:

  • Identifiers, such as your email address. This information is collected directly from you.

We collect and disclose your personal information, including sensitive personal information, for the following purposes:

  • To provide you with the Website
  • To register you for our newsletter which contains Game news and updates, if you sign up for such newsletter.
  • To monitor the performance of, and to improve, our services.

For additional information about what each type of personal information is used for, see Section 3 (How We Process Your Personal Information).

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.

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 the chart in Section 6 (Date Retention) 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.

  • Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:
    • the categories of personal information about you that we collected;
    • the categories of sources from which the personal information was collected;
    • the business or commercial purposes for collecting personal information about you;
    • the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
    • the specific pieces of personal information we collected about you;
  • Request to Delete. Request we delete personal information we collected about you;
  • Request to Correct. Request we correct inaccurate personal information that we maintain about you; and
  • Right to Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.

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 as specified in Section 8 (Contact). 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 the following information from you: your first name, last name, address, phone number, date of birth and email address.

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 as set out in Section 8 (Contact).