BLACKJACK21's Privacy Policy

Last updated: 4 Mar 2022

Neongames Co. ('Neongames') is committed to protecting your privacy.
We also provide services in compliance with international standards such as the GDPR's privacy guidelines.
We collect your personal information based on your consent to provide you with direct control over the information,
which can be withdrawn at any time. In addition, when revising or changing your personal information processing policy,
we notify the contents at the bottom of the homepage and you can check the policy from time to time under the setting of the game at any time.

BLAKCJACK21's personal information processing policy contains the following contents.

1. Information to be colleted
2. Use of collected information
3. Sharing collected information
4. Social sharing features
5. Push notifications
6. Children
7. Security
8. Your rights
9. Personal information consent for marketing use
10. Contact and complaints
11. Neongames right to change privacy policy

1. Information to be colleted

Types of information we collect:

1) Non-personal information

Non-personal information refers to information that cannot be used to identify a specific individual.
Neongames may collect non-personal information from you during your use of the Services,
including your IP address, referral data, browser type, browser language, platform type, type of mobile device, and geographical data, such as zip code and geographic location.

2) Personal data information

Personal data information means information that is specific to you and can be used to contact or identify you.
Specifically, we may receive from Facebook certain personal data about you, such as your user name, date of birth, email address, and profile picture
when you use the Services, or you may voluntarily disclose such information to us in the use of the Services.
Any information directly collected through your Facebook account and shared with us will be collected,
used and stored in a manner commercially reasonably similar to the privacy policy of Facebook in effect at the time of collection
and in compliance with any specific privacy settings set by you of whom we are aware.
Please note that because a third party site manages the purchases of Virtual Currency or Virtual Goods for use with the Services,
Neongames does not have access to your credit card or billing information.

2. Use of collected information

1) Use of non-personal information

Neongames collects this non-personal information for purposes of tracking and analyzing user preferences and trends in order to improve the quality and design of the Services and to create new features, promotions, and functionalities;
for editorial and feedback purposes; for marketing and promotional purposes; for content improvement; and to customize the Services.
This information may also be shared with advertisers and our business partners on an aggregated non-personal basis.

2) Use of personal data information

We will use this personal data information to fulfill your requests for our services, to process and respond to your inquiries, to improve the Services, and to offer you other opportunities that we think may be of interest to you.
In addition, Neongames may use the personal data information to communicate with you regarding new products, new features, product updates and enhancements or special offers or promotions.
If you enter any contests, sweepstakes or promotions in connection with the Services, Neongames may use the information you provide in the administration of the contest, sweepstakes or promotion.
By participating in online tournaments or contests, you agree to allow Neongames to collect, use, store, transmit and publicly display your scores and rankings in the tournament or contest.

3) Cookie

While you are using the Services, our web servers may seek to place a "cookie"(a small data file) on your mobile device, computer or other participating device.
This cookie is not used to obtain your name or any personal data, and the information that is tracked is used only for internal purposes, such as to improve the Services.
If you prefer not to accept cookies, you can set your web browser on your computer to reject them or to alert you before one is placed,
but some of our features and services may not function properly if you disable cookies.
Certain areas of our site use advertising companies to display advertisements.
These ads may also contain cookies and Neongames does not have access to this information.
The Company agrees that it will obtain consent from the users, if the Company desires to use the information other than those expressly stated in this Policy.

3. Sharing collected information

Neongames will not disclose your personal information to third parties except in the following circumstances:

1) We may disclose personal data information in response to legal process, for example, in response to a court order or a subpoena

2) We also may disclose such information in response to a law enforcement agency's request,
or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities,
suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.

3) We may transfer information about you if we are acquired by or merged with another company or in the unlikely event that Neongames is dissolved.

4) If we need to share your information to provide the product or service you have requested.

5) If we need to send the information to companies who work on behalf of Neongames to provide a product or service to you.
(Unless we tell you differently, these companies do not have any right to use the personal data information we provide to them beyond what is necessary to assist us.)

However, except as described above, we will not trade, exchange or sell your personal data information with any other third party.

4. Social sharing features

The services offers social sharing features and other integrated tools (such as the Facebook 'Like' button), which let you share actions you take in the Services with other media.
You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in the Services.
The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.

The Services has social features from the following providers:

- Facebook

For more information about the processing carried out by the respective third parties in connection with social sharing features,
please visit the privacy policies of the entities that provide these features, which can be found here: https://www.facebook.com/about/privacy/

5. Push notification

We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications.
You can deactivate these notifications by changing your notification settings on your device.

6. Children

Neongames's Web site is not intended for or marketed to persons under the age of 21.
Neongames does not collect or post information from children under the age of 13. If we learn that we have collected personal information from a child under age 13,
we will delete that information as quickly as possible.

If you have additional questions about BLACKJACK21's privacy practices related to children,
please contact us at k@neongames.co.kr

7. Security

We will only collect and use personal data information in accordance with this Privacy Policy to the extent deemed reasonably necessary to serve our legitimate business purposes,
and we will maintain appropriate safeguards to ensure the security, integrity, accuracy and privacy of the information you have provided.

8. Your rights

If you wish to use any of the rights described below, you may contact us at any time by emailing us at k@neongames.co.kr
We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request.
In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.

1) Right to request access

You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:

- the purposes of the processing
- the categories of personal data concerned
- the recipients or categories of recipient to whom the personal data have been or will be disclosed
- the envisaged period for which the personal data will be stored

Furthermore, you have the right to obtain a copy of the personal data undergoing processing.
Please note that the access may be restricted due to intellectual property or trade secrets.

2) The right to object

You have the right to object to our processing of your personal data on grounds relating to your particular situation
when the data are processed based on the balancing-of interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR.
In this case, we will cease the processing unless there is compelling legitimate grounds for the processing
which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes at any time.
We will cease the processing of your personal data for this purpose after the objection.
Please note that if you exercise this right, your user license to use the Services will cease automatically.

3) Right to rectification and erasure

You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR:

- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
- if you have withdrawn your consent and there are no other legal grounds for the processing,(br) - if you have objected to the processing and there are no overriding legitimate grounds for the processing,
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law,
- the personal data have been unlawfully processed or
- the personal data have been collected in relation to the offer of information society services.

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.

4) Right to withdraw consent

You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR.
If you have the right to restriction, we will only process your data with your consent or for the establishment,
exercise or defense of a legal claim or to protect a person or important grounds of public interest the right to withdraw consent.
If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.
If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.
Please note that if you withdraw your consent, your user license to use the Services will cease automatically.
The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

5) The right to data portability

You have the right to receive the personal data you have provided us with which we process in a structured,
commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.

9. Personal information consent for marketing use

You may refuse to accept any optional collection, use, or provision. If you do not agree, there may be restrictions on the benefits of using the related facilities (including free virtual currency, new products and services, events).
There are no other disadvantages associated with contracting.
If you agree, you may also ask us to withdraw your consent or stop contacting you for marketing purposes.

1) Purpose: Providing convenience to customers, advising your service
2) Items:
- Personally Identifiable information: Name, Sex, Country, E-MAIL Address
- Customer ID, connection date and time
3) Period of use: Retention / transfer from the date of consent to withdrawal of membership or withdrawal of marketing agreement

10. Contact and complaints

Neongames has designated the person in charge of personal information protection and the person in charge as below for inquiries and complaints about personal information of users.

1) Personal information protection director

- Name: Kiyork Kim (Privacy & Security)
- Position: CEO, CPO
- Address: NEOWIZ PANGYO TOWER 6th Fl, 14, Daewangpangyo-ro 645 beon-gil, Bundang-gu, Seongnam-si, Gyeonggi-do, 13487, Republic of Korea,
- Phone: +82-31-698-3448
- E-mail: k@neongames.co.kr

2) Personal information protection officer

- Name: Jaesick Jung (Privacy & Security)
- Position: Manager, DPO
- Address: NEOWIZ PANGYO TOWER 6th Fl, 14, Daewangpangyo-ro 645 beon-gil, Bundang-gu, Seongnam-si, Gyeonggi-do, 13487, Republic of Korea,
- Phone: +82-31-698-3448
- E-mail: jjs7467@neongames.co.kr

If you wish to make a complaint over the processing of your personal data, you have the right to lodge a complaint to the relevant supervisory authority.

11. Neongames right to change privacy policy

Neongames reserves the right to change this policy at any time. It is your responsibility to check the policy for any changes.
Our privacy policy will indicate the date it was last updated.
Your continued use of our site will signify your acceptance of the changes to our online privacy policy.