SHIFT UP Corporation (the “Company” or “SHIFT UP”) takes the protection of users’ personal information seriously and complies with applicable laws and regulations, such as the Personal Information Protection Act and the Act on Promotion of Information and Communications Network Utilization and Information Protection. Through this Privacy Policy (this “Policy”), the Company hereby informs users of the purposes and methods of its use of the personal information provided by users and the measures taken to protect such personal information.
The Company discloses this Policy on the homepage of SHIFT UP website (https://shiftup.co.kr) to ensure that users can easily access it at any time.
This Policy may be amended due to changes in applicable laws and regulations and guidelines, or changes in the Company’s internal policies.
Article 1 (Items of Personal Information to be Collected and Used and Method of Collection)
1. When users use the Company’s game services, the Company receives the following personal information of users from third parties. When users use certain additional services, the Company notifies the users of such fact and obtain additional consent from them.
1) (Mandatory) If users use services linked to an external platform, unique number provided by the external platform
2) (Mandatory) If users use social media services, contact information such as profile name, profile photo, friend list, etc. (In this case, the Company only uses the third parties’ information temporarily and does not store it)
3) (Mandatory) If users apply for the issuance of an exchange code that can be used in the “GODDESS OF VICTORY: NIKKE”, "胜利女神：新的希望".
| Provider |
Personal Information to be Provided |
| Sony Interactive Entertainment |
PlayStation™ Network Account ID |
Purchase history and playtime records for the Complete Edition of Stellar Blade |
| Value Corporation |
Steam® Account ID |
| Epic Games, Inc. |
Epic Games Account ID |
2. If users use customer services to facilitate their use of the Company’s services, the Company collects the following personal information with their consent.
1) If users use customer consulting services:
(Mandatory) Email address, game membership number (or unique number provided by an external platform)
2) If users request a refund:
(Mandatory) Email address, game membership number (or unique number provided by an external platform), (in the case of using Google) Google email ID, purchase history details, user’s real name or certificate of family relations to confirm payment by a party other than the principal
- In case of a cash refund due to termination of game services:
(Mandatory) Name, mobile phone number, (in the case of using Google Store) payment account, bank name, bank account number, account holder name, email, copy of identification card, copy of bankbook
3) If users participate in events or promotions:
- In case of participation in events:
(Mandatory) mobile phone number, (if the event is conducted via social media services) social media services account ID
- In case of delivery of event prizes:
(Mandatory) Name, mobile phone number, address, etc.
- In case of imposition of taxes and public charges on event winners
(Mandatory) Resident registration number, address, and name
3. In the course of users’ use of the Company’s services, the Company may automatically generate and collect following information for the purposes of complying with laws, protecting users’ accounts and items, preventing fraudulent use by users, and providing stable services:
Information about the user’s mobile device (e.g., model name, OS version, mobile firmware version, device identification number, etc.), IP address, cookies, last access location, location-based service use records, access date and time, service use records, and improper usage records, etc.
4. Methods of collection of personal information
The Company collects personal information through the following methods:
- Collection through the consent process during the sign-up for the Company’s services
- Collection through a separate consent process for promotions and events
- Automatic collection through platforms with which the Company has a partnership for service provision
- Collection through the user’s voluntary provision or upon request during customer service interactions for the sign-up and use of services
Article 2 (Purpose of Use of Personal Information)
The Company uses personal information collected from users for the following purposes:
- To provide services, including identifying users and verifying their identity
- To respond to customer center inquiries, address complaints, and improve user services
- To notify users of promotions such as events
- To confirm users’ intent to participate in events, deliver prizes to event participants, and handle taxes and public charges, etc.
- To prevent unlawful subscriptions and use
- To analyze the service use environment through service use records, improve the services, and provide the services based on the characteristics of users
The users’ consent, as the data subject, to the processing as specified in this Policy is the primary legal ground for our processing of the users’ personal information. However, there may be circumstances where the Company may also rely on other valid legal grounds for the processing of the users’ personal information, such as:
- the users’ request for content, goods or services necessitating steps including processing of the users’ personal information to be taken prior to entering into contract with the users and any processing that is necessary for the performance of such contract; and
- legitimate interests pursued by the Company as a business, except where such interests are overridden by the users’ interests and fundamental rights. The Company will rely on this legal ground in relation to the processing set out in paragraphs above, in which the Company have a legitimate interest; and
- compliance with a legal obligation to which the Company are subject, such as, for example, the processing for the purposes set out above.
Article 3 (Provision of Personal Information)
1) In no event will the Company use users’ personal information beyond the scope specified in Article 2 (Purpose of Use of Personal Information) or provide it to any other person, company, organization or institution, except with the consent of the users or in accordance with the provisions of relevant laws and regulations.
2) When providing users’ personal information to a third party—such as when it is necessary to provide limited user information to a business partner or a business operator with which the Company has partnerships for the purpose of providing various services—the Company will inform users of the recipient’s name, the recipient’s main business, the items of personal information to be provided, and the purpose for providing the personal information. User consent will be obtained prior to any such disclosure.
3) In any of the following cases, the Company may provide users’ personal information without the consent from the users in accordance with the relevant laws and regulations:
(1) Where it is necessary to compile statistics or conduct scientific research, and if the information is processed and provided in a form in which a specific individual cannot be identified;
(2) Where there is a special provision in the Act on Real Name Financial Transactions and Confidentiality, the Credit Information Use and Protection Act, the Framework Act on Telecommunications, the Telecommunications Business Act, the Local Tax Act, the Consumer Protection Act, the Bank of Korea Act, the Criminal Procedure Act, or any other laws.
Article 4 (Period of Retention and Use of Personal Information)
1) In principle, the Company will destroy personal information immediately after the purpose of collecting and using the personal information has been achieved. The processing and retention periods for personal information in each specific case are outlined below. If a user provides separate consent, their personal information will be retained for the period specified in that consent.
(1) If users apply for the issuance of an exchange code that can be used in the “GODDESS OF VICTORY: NIKKE.”, "胜利女神：新的希望": One (1) year
(2) If the Company intends to prevent any fraudulent use: One (1) year
2) If it is necessary to retain the users’ personal information pursuant to the relevant laws and regulations, the Company will retain the users’ personal information for the period set forth in the relevant laws and regulations as follows:
If it is necessary to retain the information pursuant to the relevant laws and regulations
- Records on labeling and advertisement
Legal ground for retention: Article 6 of the Act on the Consumer Protection in Electronic Commerce and Article 6 of the Enforcement Decree of the same Act
Retention period: Six (6) months
- Records on contract or withdrawal of application, etc.
Legal ground for retention: Article 6 of the Act on the Consumer Protection in Electronic Commerce and Article 6 of the Enforcement Decree of the same Act
Retention period: Five (5) years
- Records on payment and supply of goods, etc.
Legal ground for retention: Article 6 of the Act on the Consumer Protection in Electronic Commerce and Article 6 of the Enforcement Decree of the same Act
Retention period: Five (5) years
- Records on consumer complaints or disputes handling
Legal ground for retention: Article 6 of the Act on the Consumer Protection in Electronic Commerce and Article 6 of the Enforcement Decree of the same Act
Retention period: Three (3) years
- Records on collection, processing, use, etc. of credit information
Legal ground for retention: Article 20 of the Credit Information Use and Protection Act
Retention period: Three (3) years
- Records on access
Legal ground for retention: Article 15-2 of the Protection of Communications Secrets Act and Article 41 of the Enforcement Decree of the same Act
Retention period: Three (3) months
3) If users request access to the personal information, etc. retained in accordance with paragraphs 1) and 2) above, the Company will immediately take actions to ensure that the users can access and confirm the details thereof.
Article 5 (Procedures and Methods for Destruction of Personal Information)
In principle, the Company will destroy personal information immediately after the purpose of collecting and using the personal information has been achieved. The procedures and methods for destruction of the personal information are outlined below.
1) After the purpose provided by the user in the course of using the services is achieved, the user’s personal information is transferred to a separate DB and stored for a certain period of time and then destroyed in accordance with the reasons for information protection under applicable laws and regulations (see Article 4 (Period of Retention and Use of Personal Information)). Personal information will not be used for any purpose other than retention unless otherwise required by law.
2) Personal information stored in electronic files is deleted using a technical method that prevents the recovery of records. Personal information printed on paper is destroyed by shredding or incineration.