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Terms & Condition :

1. INTRODUCTION

1.1 Welcome to Garena. These Terms of Service set out the terms and conditions by which Garena Online Private Limited and its affiliates and subsidiaries (individually and collectively, "Garena", "we", "us" or "our") offer:
(a) our PC and mobile games (“Games”);
(b) the underlying Games client software and the Garena PC and mobile platform client software (“Software”);
(c) this website, including the Garena Shop (“Site”); and
(d) any other apps, websites, games or services that link to this Terms of Service, regardless of how you access or use them, including through mobile devices,
(collectively, the “Services”).
1.2 The Services also include any services provided by or through the Garena platform client software, any services made available through our Games or the Site, and all information, linked pages, features, data, text, images, photographs, graphics, music, sounds, video, messages, tags, content, programming, software, application services (including without limitation any mobile application services) or other materials made available by or through us ("Content"). Any updates, upgrades and new features added to or augmenting the Services are also subject to these Terms of Service.
1.3 Please read these Terms of Service carefully before using the Services or opening a Garena account ("Account") so that you are aware of your legal rights and obligations with respect to Garena.
1.4 BY USING THE SERVICES OR OPENING AN ACCOUNT, YOU SIGNIFY YOUR IRREVOCABLE ACCEPTANCE OF THESE TERMS OF SERVICE. IF YOU DO NOT AGREE TO THESE TERMS, PLEASE DO NOT USE OUR SERVICES. IF YOU ARE YOUNGER THAN 18 YEARS OLD OR THE RELEVANT "AGE OF MAJORITY" WHERE YOU LIVE, YOU MUST GET PERMISSION FROM A PARENT OR LEGAL GUARDIAN TO OPEN AN ACCOUNT AND THAT PARENT OR LEGAL GUARDIAN MUST AGREE TO THESE TERMS OF SERVICE. IF YOU DO NOT KNOW WHETHER YOU HAVE REACHED THE "AGE OF MAJORITY" WHERE YOU LIVE, OR DO NOT UNDERSTAND THIS SECTION, PLEASE DO NOT CREATE AN ACCOUNT UNTIL YOU HAVE ASKED YOUR PARENT OR LEGAL GUARDIAN FOR HELP. IF YOU ARE THE PARENT OR LEGAL GUARDIAN OF A MINOR WHO IS CREATING AN ACCOUNT, YOU MUST ACCEPT THESE TERMS OF SERVICE ON THE MINOR'S BEHALF AND YOU WILL BE RESPONSIBLE FOR ALL USE OF THE ACCOUNT OR SERVICES, INCLUDING PURCHASES MADE BY THE MINOR, WHETHER THE MINOR'S ACCOUNT IS NOW OPEN OR CREATED LATER AND WHETHER OR NOT THE MINOR IS SUPERVISED BY YOU DURING SUCH PURCHASE.
1.5 Garena has the right to revise these Terms of Service at any time without providing notice to its users. It is your responsibility to check this page regularly to make note of any changes. Your continued use of the Services shall be deemed irrevocable acceptance of those revisions.
1.6 Garena reserves the right to change, modify, suspend or discontinue any portion of the Services at any time. Garena may release certain Services or their features in a beta version, which may not work correctly or in the same way the final version may work, and we shall not be held liable in such instances. Garena may also impose limits on certain features or restrict your access to parts of, or the entire, Services in its sole discretion and without notice or liability.
1.7 Garena reserves the right to refuse to provide you access to the Services or to allow you to open an Account for any reason.

2. PRIVACY

2.1 Your privacy is very important to us at Garena. To better protect your rights, we have provided the Garena Privacy Policy to explain our privacy practices in detail. Please review the Privacy Policy to understand how Garena collects and uses the information associated with your Account and/or your use of the Services. By using the Services or agreeing to these Terms of Service, you consent to Garena's collection, use, disclosure and/or processing of your Content and personal data as described in the Privacy Policy.
3. LIMITED LICENSE

3.1 Garena grants you a non-exclusive, non-transferable limited right and license to install the Software and access and use the Services, subject to the terms and conditions of these Terms of Service and for personal use only. This license does not allow you to make any commercial use or any derivative use of the Services (including without limitation any of its individual elements, including but not limited to the Games, Software or Content). All rights not specifically granted by Garena under these Terms of Service are hereby reserved by Garena. Any third-party scripts or code, linked to or referenced from the Services, are licensed to you by the third parties that own such scripts or code, not by Garena.
3.2 You acknowledge and agree that all title, ownership rights and intellectual property rights connected with the Services (including but not limited to any derivative works, titles, computer code, objects, themes, characters, character names, stories, dialogues, catch phrases, locations, concepts, artwork, graphics, animation, sounds, musical compositions, audio-visual effects, text, screen displays, methods of operation, moral rights, “applets” incorporated in the Services, and any related documentation) are the property of Garena and where applicable, third party proprietors identified in the Services.
3.3 By using or accessing the Services you agree to comply with the copyright, trademark, service mark, and all other applicable laws that protect the Services and its Content. You agree not to copy, distribute, republish, transmit, publicly display, publicly perform, modify, adapt, rent, sell, or create derivative works of any portion of the Services or its Content. You also may not, without our prior written consent, mirror or frame any part or whole of the Services on any other server or as part of any other website. In addition, you agree that you will not use any robot, spider or any other automatic device or manual process to monitor or copy our Content, without our prior written consent (such consent is deemed given for standard search engine technology employed by Internet search websites to direct Internet users to this website).
3.4 You are welcome to link to the Site from your website, provided that your website does not imply any endorsement by or association with Garena. You acknowledge that Garena may, in its sole discretion and at any time, discontinue providing any part of the Services without notice.
4. TERMS OF USE

4.1 The license for use of the Services is effective until terminated as set forth in these Terms of Service or if you fail to comply with any term or condition of these Terms of Service. In such event, no notice shall be required by Garena to effect such termination.
4.2 You agree not to:
(a) upload, post, email, transmit or otherwise make available any Content that is unlawful, harmful, threatening, abusive, harassing, alarming, distressing, tortuous, defamatory, vulgar, obscene, libelous, invasive of another's privacy, hateful, or racially, ethnically or otherwise objectionable;
(b) use the Services to harm minors in any way;
(c) use the Services to impersonate any person or entity, or otherwise misrepresent your affiliation with a person or entity;
(d) forge headers or otherwise manipulate identifiers in order to disguise the origin of any Content transmitted through the Services;
(e) remove any proprietary notices from the Services;
(f) cause, permit or authorize the modification, creation of derivative works, or translation of the Services without the express permission of Garena;
(g) use the Services for any commercial purpose or the benefit of any third party or any manner not permitted by the licenses granted herein;
(h) use the Services for fraudulent purposes;
(i) attempt to decompile, reverse engineer, disassemble or hack the Services (or any portion thereof), or to defeat or overcome any encryption technology or security measures implemented by Garena with respect to the Services and/or data transmitted, processed or stored by Garena;
(j) harvest or collect any information about or regarding other Account holders, including without limitation any personal data or information;
(k) upload, post, email, transmit or otherwise make available any Content that you do not have a right to make available under any law or under contractual or fiduciary relationships (such as inside information, proprietary and confidential information learned or disclosed as part of employment relationships or under nondisclosure agreements);
(l) upload, post, email, transmit or otherwise make available any Content that infringes any patent, trademark, trade secret, copyright or other proprietary rights of any party;
(m) upload, post, email, transmit or otherwise make available any unsolicited or unauthorised advertising, promotional materials, "junk mail," "spam," "chain letters," "pyramid schemes," or any other unauthorised form of solicitation;
(n) upload, post, email, transmit or otherwise make available any material that contains software viruses, worms, Trojan-horses or any other computer code, routines, files or programs designed to directly or indirectly interfere with, manipulate, interrupt, destroy or limit the functionality or integrity of any computer software or hardware or data or telecommunications equipment;
(o) disrupt the normal flow of dialogue, cause a screen to "scroll" faster than other users of the Services are able to type, or otherwise act in a manner that negatively affects other users' ability to engage in real time exchanges;
(p) interfere with, manipulate or disrupt the Services or servers or networks connected to the Services or any other user's use and enjoyment of the Services, or disobey any requirements, procedures, policies or regulations of networks connected to the Services;
(q) take any action or engage in any conduct that could directly or indirectly damage, disable, overburden, or impair the Services or the servers or networks connected to the Services;
(r) use the Services to intentionally or unintentionally violate any applicable local, state, national or international law, rule, code, directive, guideline, policy or regulation including without limitation laws and requirements (whether or not having the force of law) relating to anti-money laundering or counter-terrorism;
(s) use the Services to provide material support or resources (or to conceal or disguise the nature, location, source, or ownership of material support or resources) to any organization(s) designated by the United States government as a foreign terrorist organization pursuant to section 219 of the Immigration and Nationality Act;
(t) use the Services to violate the privacy of others or to "stalk" or otherwise harass another; and/or
(u) use the Services to collect or store personal data about other users in connection with the prohibited conduct and activities set forth above.
4.3 You understand that all Content, whether publicly posted or privately transmitted, is the sole responsibility of the person from whom such Content originated. This means that you, and not Garena, are entirely responsible for all Content that you upload, post, email, transmit or otherwise make available through the Services. Garena does not control the Content posted through the Services and, as such, does not guarantee the accuracy, integrity or quality of such Content. You understand that by using the Services, you may be exposed to Content that you may consider to be offensive, indecent or objectionable. Under no circumstances will Garena be liable in any way for any Content, including, but not limited to, any errors or omissions in any Content, or any loss or damage of any kind incurred as a result of the use of, or reliance on, any Content posted, emailed, transmitted or otherwise made available through the Services.
4.4 You acknowledge that Garena may or may not pre-screen Content, but that Garena and its designees shall have the right (but not the obligation) in their sole discretion to pre-screen, refuse, delete or move any Content that is available through the Services for any reason. Without limiting the foregoing, Garena and its designees shall have the right to remove any Content that violates these Terms of Service, if we receive a complaint from another user, if we receive a notice of intellectual property infringement or other legal instruction for removal, or if such Content is otherwise objectionable. We may also block delivery of a communication (including without limitation status updates, postings, messages and/or chats) to or from the Services as part of our effort to protect the Services or our users, or otherwise enforce the provisions of these Terms and Conditions. You agree that you must evaluate, and bear all risks associated with, the use of any Content, including, without limitation, any reliance on the accuracy, completeness, or usefulness of such Content. In this regard, you acknowledge that you may not rely on any Content created by Garena or submitted to Garena, including without limitation information in Garena forums, instant messaging channels and in all other parts of the Services.
4.5 You acknowledge, consent and agree that Garena may access, preserve and disclose your Account information and Content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over Garena or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce these Terms of Service; (c) respond to claims that any Content violates the rights of third parties; (d) respond to your requests for customer service; or (e) protect the rights, property or personal safety of Garena, its users and/or the public.

5. SOFTWARE UPDATES AND PATCHES

5.1 We may provide updates, patches and other modifications to the Services that must be installed for you to continue to play our Games properly or at all. We may update, patch or modify the Software remotely and access the Software residing on your machine or device for such purpose, and you hereby grant to Garena the right to deploy and apply such patches, updates and modifications. All provisions of these Terms of Service that refer to “Software” shall also include all such patches, updates and modifications.
6. ACCOUNTS AND SECURITY

6.1 Some functions of our Services require registration for an Account by selecting a unique user identification ("User ID") and password, and by providing certain personal information. If you select a User ID that Garena, in its sole discretion, finds offensive or inappropriate, Garena has the right to suspend or terminate your Account. You may be able to use your Account to gain access to other products, websites or services to which we have enabled access or with which we have tied up or collaborated. Garena has not reviewed, and assumes no responsibility for any third party content, functionality, security, services, privacy policies, or other practices of those products, websites or services. If you do so, the terms of service for those products, websites or services, including their respective privacy policies, if different from these Terms of Service and/or our Privacy Policy, may also apply to your use of those products, websites or services.
6.2 You agree to (a) keep your password confidential and use only your User ID and password when logging in, (b) ensure that you log out from your account at the end of each session, (c) immediately notify Garena of any unauthorised use of your User ID and/or password, and (d) ensure that your Account information is accurate and up-to-date. You are fully responsible for all activities that occur under your User ID and Account even if such activities or uses were not committed by you. Garena will not be liable for any loss or damage arising from unauthorised use of your password or your failure to comply with this Section.
6.3 You agree that Garena may for any reason, in its sole discretion and without notice or liability to you or any third party, immediately terminate your Account and your User ID, and remove or discard from the Services any Content associated with your Account and User ID. Grounds for such termination may include, but are not limited to, (a) extended periods of inactivity, (b) violation of the letter or spirit of these Terms of Service, (c) violation of any applicable law, (d) fraudulent, harassing, defamatory, threatening or abusive behaviour or (e) behaviour that is harmful to other users, third parties, or the business interests of Garena. Use of an Account for illegal, fraudulent, harassing, defamatory, threatening or abusive purposes may be referred to law enforcement authorities without notice to you. If you file a claim (under any cause of action whatsoever) either against Garena, or which in any way involves Garena, then Garena may terminate your Account.
6.4 If your Account is or remains inactive (which means you have not logged into your Account) for more than 6 months, Garena has the right to delete or deactivate your Account and all Shells and other in-game currency in your Account shall be forfeited.
6.5 You may only use the Services and/or open an Account if your applicable jurisdiction allows you to accept these Terms of Service.

7. CHARGES AND PAYMENTS

7.1 If there is a charge associated with the purchase of Shells or any portion of the Services, you agree to pay that charge in order to receive Shells or to receive access to and/or the benefits of such Services. The price stated for the Shells and Services excludes all applicable taxes and currency exchange settlements, unless stated otherwise. You are solely responsible for paying such taxes or other charges. We may suspend or cancel your access to the Services if we do not receive full payment from you within the stipulated due date for payment. Suspension or cancellation of the Services for non-payment could result in a loss of access to and use of your Account and its Content.
7.2 If you are in Singapore, under our Shell-borrowing plan, you can borrow and use Shells first and pay back what you have borrowed by topping up Shells to your Account within 7 days (or such other period as we may stipulate from time to time). We do not charge interest for borrowed Shells, but failure to pay for borrowed Shells on time will entitle us to suspend or cancel your access to the Services, as stated above.
7.3 To pay the charges for Shells or for a Service, you will be asked to select a payment method before you complete your purchase or at the time you sign up for that Service. You can access and change your billing account information and payment method at any time. You agree to allow Garena to use any updated account information regarding your payment method provided by your issuing bank or the applicable payment network. You agree to keep your billing account information current at all times. Changes that you make to your billing account will not affect charges we submit to your billing account before we are able to reasonably act on your changes.
7.4 By providing Garena with a payment method, you:
(a) represent that you are authorised to use the payment method that you provided and that any payment information you provide is true and accurate;
(b) authorise Garena to charge you for the Services using your preferred payment method; and
(c) authorise Garena to charge you for any paid feature of the Services that you choose to sign up for or use while these Terms of Service are in force.
7.5 Depending on the nature of the purchase, we may bill you (a) in advance; (b) at the time of purchase; (c) after purchase (and by the stipulated due date for payment) for Shells which are loaned to you under our Shell-borrowing plan (Singapore only); or (d) on a recurring basis for a subscription-based Service.
7.6 We may change the price of Shells and/or any Service at any time. If there is a fixed term and price for your Service offer, that price will remain in force for the duration of that term.
7.7 Once purchased, your Shells will be valid indefinitely until your Account is terminated for any reason or if we are no longer able to legally service your Account (for example, if you withdraw your consent for us to use your personal data). If your Account is or remains inactive (which means you have not logged into your Account) for more than 6 months, Garena has the right to delete or deactivate your Account and all Shells in your Account, and other in-game currency in your Games, shall be forfeited.
7.8 Unless otherwise provided by applicable law or by the express terms of a Service offer, all purchases are final and non-refundable. You may cancel any Services at any time, but all pre-payments and all purchased Shells are strictly non-refundable.

8. MEMBERSHIP SUBSCRIPTIONS

8.1 We may offer membership subscription plans in our Games (“Subscriptions”). Subscriptions may be weekly, monthly or such other recurring period as determined by us and notified in our Games (“Subscription Period”).
8.2 Subscriptions may be purchased by paying the fee specified in our Games (“Subscription Fee”) and are subject to the terms and conditions in Clause 7 above and the additional terms and conditions published within our Games.
8.3 Subscriptions will be automatically renewed for further Subscription Periods, and you will be charged the Subscription Fee, at the end of each Subscription Period until cancelled by you. As we will not notify you prior to such renewal, you are advised to monitor your Subscriptions.
8.4 You may cancel your Subscription at any time through Google Play or the App Store (as the case may be). Upon cancellation, your Subscription shall not be renewed and shall expire on the last day of the Subscription Period. In the event your Subscription Fee or any part of it is refunded, we reserve the right to deduct any in-game currencies or items previously granted by us in the Subscription Period prior to your cancellation taking effect.
8.5 We may allow you to subscribe for more than one Subscription at a time. Subscriptions may have limited availability. Once Subscriptions are fully subscribed, they may no longer be made available for purchase. We reserve the right to make changes to our Subscriptions at any time.
9. DISCLAIMER

9.1 THE SERVICES ARE PROVIDED "AS IS" AND WITHOUT ANY WARRANTIES, CLAIMS OR REPRESENTATIONS MADE BY GARENA OF ANY KIND EITHER EXPRESS, IMPLIED OR STATUTORY WITH RESPECT TO THE SERVICES, INCLUDING WITHOUT LIMITATION WARRANTIES OF QUALITY, PERFORMANCE, NON-INFRINGEMENT, MERCHANTABILITY, OR FITNESS FOR A PARTICULAR PURPOSE, NOR ARE THERE ANY WARRANTIES CREATED BY COURSE OF DEALING, COURSE OF PERFORMANCE OR TRADE USAGE. WITHOUT LIMITING THE FOREGOING, GARENA DOES NOT WARRANT THAT THE SERVICES OR THE FUNCTIONS CONTAINED THEREIN WILL BE AVAILABLE, ACCESSIBLE, UNINTERRUPTED, TIMELY, SECURE, ACCURATE, COMPLETE OR ERROR-FREE, THAT DEFECTS, IF ANY, WILL BE CORRECTED, OR THAT THE SERVICES AND/OR THE SERVER THAT MAKES SAME AVAILABLE ARE FREE OF VIRUSES, CLOCKS, TIMERS, COUNTERS, WORMS, SOFTWARE LOCKS, DROP DEAD DEVICES, TROJAN-HORSES, ROUTINGS, TRAP DOORS, TIME BOMBS OR ANY OTHER HARMFUL CODES, INSTRUCTIONS, PROGRAMS OR COMPONENTS. YOU ACKNOWLEDGE THAT THE ENTIRE RISK ARISING OUT OF THE USE OR PERFORMANCE OF THE SERVICES REMAINS WITH YOU TO THE MAXIMUM EXTENT PERMITTED BY LAW.
9.2 Some jurisdictions do not allow the disclaimer of implied warranties, so some or all of the foregoing disclaimers may not apply to you.
10. EXCLUSIONS AND LIMITATION OF LIABILITY

10.1 IN NO EVENT SHALL GARENA BE LIABLE WHETHER IN CONTRACT, WARRANTY, TORT (INCLUDING WITHOUT LIMITATION NEGLIGENCE (WHETHER ACTIVE, PASSIVE OR IMPUTED), PRODUCT LIABILITY OR STRICT LIABILITY OR OTHER THEORY), OR OTHER CAUSE OF ACTION AT LAW, IN EQUITY, BY STATUTE OR OTHERWISE, FOR LOSS OF USE, PROFITS, REVENUES, GOODWILL OR ANTICIPATED SAVINGS OR FOR ANY INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES (INCLUDING WITHOUT LIMITATION ANY LOSS OF DATA, SERVICE INTERRUPTION, COMPUTER, MOBILE PHONE OR MOBILE DEVICE FAILURE) ARISING OUT OF OR IN CONNECTION WITH THE USE OR INABILITY TO USE THE SERVICES, INCLUDING, WITHOUT LIMITATION, ANY DAMAGES RESULTING THEREFROM, EVEN IF GARENA HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
10.2 YOUR ONLY RIGHT WITH RESPECT TO ANY PROBLEMS OR DISSATISFACTION WITH THE SERVICES IS TO TERMINATE YOUR ACCOUNT AND DISCONTINUE ANY USE OF THE SERVICES.
10.3 IF, NOTWITHSTANDING THE PREVIOUS SECTIONS, GARENA IS FOUND BY A COURT OF COMPETENT JURISDICTION TO BE LIABLE (INCLUDING FOR GROSS NEGLIGENCE), ITS LIABILITY TO YOU OR TO ANY THIRD PARTY IS LIMITED TO SGD 100 (ONE HUNDRED SINGAPORE DOLLARS).
10.4 NOTHING IN THESE TERMS OF SERVICE SHALL LIMIT OR EXCLUDE ANY LIABILITY FOR DEATH OR PERSONAL INJURY CAUSED BY GARENA’S NEGLIGENCE, FOR FRAUD OR FOR ANY OTHER LIABILITY THAT CANNOT BE LAWFULLY LIMITED AND/OR EXCLUDED.

11. LINKS TO THIRD PARTY SITES

11.1 Any links provided through the Services will let you leave the Site or Games. These links are provided as a courtesy only, and the sites they link to are not under the control of Garena in any manner whatsoever and you therefore access them at your own risk. Therefore, Garena is in no manner responsible for the contents of any such linked site or any link contained within a linked site, including any changes or updates to such sites. Garena is providing these links merely as a convenience, and the inclusion of any link does not in any way imply or express affiliation, endorsement or sponsorship by Garena of any linked site and/or any of its content therein.
12. YOUR CONTRIBUTIONS TO THE SERVICES

12.1 By submitting Content for inclusion on the Services, you represent and warrant that you have all necessary permissions to grant the licenses below to Garena. You further acknowledge and agree that you are solely responsible for anything you post or otherwise make available on or through the Services, including, without limitation, the accuracy, reliability, nature, rights clearance, compliance with law and legal restrictions associated with any Content contribution. You hereby grant Garena and its successors an irrevocable, worldwide, non-exclusive, royalty-free, sub-licensable and transferable license to use, copy, distribute, republish, transmit, modify, adapt, create derivative works of, publicly display, and publicly perform such Content contribution on, through or in connection with the Services in any media formats and through any media channels, including without limitation, for promoting and redistributing part of the Services (and its derivative works). You understand that your contribution may be transmitted over various networks and changed to conform and adapt to technical requirements.
12.2 Any material, information or idea you post on or through the Services, or otherwise transmit to Garena by any means (each, a "Submission"), is not considered confidential by Garena and may be disseminated or used by Garena or its affiliates without compensation or liability to you for any purpose whatsoever, including, but not limited to, developing, manufacturing and marketing products. By making a Submission to Garena, you acknowledge and agree that Garena and/or other third parties may independently develop software, applications, interfaces, products and modifications and enhancements of the same which are identical or similar in function, code or other characteristics to the ideas set out in your Submission. Accordingly, you hereby grant Garena and its successors an irrevocable, worldwide, non-exclusive, royalty-free, sub-licensable and transferable license to develop the items identified above, and to use, copy, distribute, republish, transmit, modify, adapt, create derivative works of, publicly display, and publicly perform any Submission on, through or in connection with the Services in any media formats and through any media channels, including without limitation, for promoting and redistributing part of the Services (and its derivative works). This license granted by you will continue for as long as Garena determines to use your Submission. This provision does not apply to personal information that is subject to our privacy policy except to the extent that you make such personal information publicly available on or through the Services.

13. THIRD PARTY CONTRIBUTIONS TO THE SERVICES AND EXTERNAL LINKS

13.1 Each contributor to the Services of data, text, images, sounds, video, software and other Content is solely responsible for the accuracy, reliability, nature, rights clearance, compliance with law and legal restrictions associated with their Content contribution. As such, Garena is not responsible to, and shall not, regularly monitor or check for the accuracy, reliability, nature, rights clearance, compliance with law and legal restrictions associated with any contribution of Content. You will not hold Garena responsible for any user's actions or inactions, including, without limitation, things they post or otherwise make available via the Services.
13.2 In addition, the Services may contain links to third party text and video feeds (and podcasts) (collectively, "third party feeds"), products, websites, services and offers, or links to download third party software applications. Additionally, third parties may make available, on their own websites, third party feeds, and software applications. These third party links, third party feeds, products, websites, services and software applications are not owned or controlled by Garena. Rather, they are operated by, and are the property of, the respective third parties, and may be protected by applicable copyright or other intellectual property laws and treaties. Garena has not reviewed, and assumes no responsibility for the content, functionality, security, services, privacy policies, or other practices of these third parties. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise. By using the Services, you agree that Garena shall not be liable in any manner due to your use of, or inability to use, any third-party feed, website or widget. You further acknowledge and agree that Garena may disable your use of, or remove, any third party links, third party feeds, or applications on the Services to the extent they violate these Terms of Service.
14. VIOLATION OF OUR TERMS OF SERVICE

14.1 If you believe a user of our Services is violating these Terms of Service, please contact us at info@garena.com
15. MAKING CLAIMS OF COPYRIGHT INFRINGEMENT

15.1 If you believe that your work (as included on the Services) has been copied, displayed, or distributed in a way that constitutes copyright infringement, please notify our Copyright Agent. A notification of claimed infringement must be a written communication as set forth below, and must include substantially all of the following:
(a) a physical or electronic signature of a person authorised to act on behalf of the owner of the copyright interest that is allegedly infringed;
(b) a description of such copyrighted work(s) and an identification of what material in such work(s) is claimed to be infringed;
(c) a description of the exact name of the infringing work and the location of the infringing work on the Services;
(d) information sufficient to permit Garena to contact you, such as your physical address, telephone number and e-mail address;
(e) a statement by you that you have a good faith belief that the use of the material identified in the manner complained of is not authorised by the copyright owner, its agent, or the law; and
(f) a statement by you that the information in the notification is accurate and, under penalty of perjury, that you are authorised to act on the copyright owner's behalf.
The Garena Copyright Agent can be reached by email: legal@garena.com
The Copyright Agent will only respond to any claims involving alleged copyright infringement.
16. YOUR REPRESENTATIONS AND WARRANTIES

16.1 You represent and warrant that:
(a) you possess the legal capacity (and in the case of a minor, valid parent or legal guardian consent), right and ability to enter into these Terms of Service and to comply with its terms;
(b) you will use the Services for lawful purposes only and in accordance with these Terms of Service and all applicable laws, rules, codes, directives, guidelines, policies and regulations; and
(c) you will only use the Services on a machine or device on which such use is authorised by the machine’s or device’s owner.

17. INDEMNITY

17.1 You agree to indemnify, defend and hold harmless Garena, and its shareholders, subsidiaries, affiliates, officers, agents, licensors, co-branders or other partners, and employees (collectively, the "Indemnified Parties"), at your expense, from and against any and all claims, actions, proceedings, and suits and all related liabilities, damages, settlements, penalties, fines, costs and expenses (including, without limitation, reasonable legal fees and other dispute resolution expenses) incurred by any Indemnified Party arising out of or relating to (a) the hosting, operation, management and/or administration of the Services by or on behalf of Garena, (b) your violation or breach of any term of these Terms of Service or any policy or guidelines referenced herein, (c) your use or misuse of the Services, or (d) your breach of any law or the rights of a third party.
18. SEVERABILITY

18.1 If any provision of these Terms of Service shall be deemed unlawful, void, or for any reason unenforceable under the law of any jurisdiction, then that provision shall be deemed severable from these terms and conditions and shall not affect the validity and enforceability of any remaining provisions in such jurisdiction nor the validity and enforceability of the provision in question under the law of any other jurisdiction.
19. GOVERNING LAW

19.1 These Terms of Service shall be governed by and construed in accordance with the laws of the Republic of Singapore without regard to its conflict of law rules. The United Nations Convention on Contracts for the International Sale of Goods and the Uniform Computer Information Transaction Act, to the extent applicable, are expressly disclaimed. Any dispute, controversy, claim or difference of any kind whatsoever shall arising out of or relating to these Terms of Service against or relating to Garena or any Indemnified Party under these Terms of Service shall be referred to and finally resolved by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this Section. There will be one (1) arbitrator and the language of the arbitration shall be English.
20. GENERAL PROVISIONS

20.1 Garena reserves all rights not expressly granted herein.
20.2 Garena may modify these Terms of Service at any time by posting the revised Terms of Service on the Site. Your continued use of the Services after such changes have been posted shall constitute your acceptance of such revised Terms of Service.
20.3 You may not assign, sublicense or transfer any rights granted to you hereunder or subcontract any of your obligations.
20.4 Nothing in these Terms of Service shall constitute a partnership, joint venture or principal-agent relationship between you and Garena, nor does it authorise you to incur any costs or liabilities on Garena’s behalf.
20.5 The failure of Garena at any time or times to require performance of any provision hereof shall in no manner affect its right at a later time to enforce the same unless the same is waived in writing.
20.6 These Terms of Service are solely for your and our benefit and are not for the benefit of any other person or entity, except for Garena's affiliates and subsidiaries (and each of Garena's and its affiliates' and subsidiaries' respective successors and assigns).
20.7 The terms set forth in these Terms of Service and any agreements and policies included or referred to in these Terms of Service constitute the entire agreement and understanding of the parties with respect to the Services and supersede any previous agreement or understanding between the parties in relation to such subject matter. The parties also hereby exclude all implied terms in fact. In entering into the agreement formed by these Terms of Service, the parties have not relied on any statement, representation, warranty, understanding, undertaking, promise or assurance of any person other than as expressly set out in these Terms of Service. Each party irrevocably and unconditionally waives all claims, rights and remedies which but for this Section it might otherwise have had in relation to any of the foregoing. These Terms of Service may not be contradicted, explained or supplemented by evidence of any prior agreement, any contemporaneous oral agreement or any consistent additional terms.
20.8 You agree to comply with all applicable laws, statutes, regulations and codes relating to anti-bribery and corruption including without limitation the UK Bribery Act, the US Foreign Corrupt Practices Act and the Singapore Prevention of Corruption Act and confirm that you have and shall have in place all policies and procedures needed to ensure compliance with such requirements.
20.9 If you have any questions or concerns about these Terms of Service or any issues raised in these Terms of Service, please contacts us at: info@garena.com.
Last modified: 11 July 2019



Privacy Policy :

1. INTRODUCTION

1.1 Welcome to the Garena website run by Garena Online Private Limited and its affiliates and related corporations (individually and collectively, "Garena", "we", "us" or "our"). Garena takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all users of our Garena games (“Games”) and website (the "Site") (we refer to the Games, Site and the services we provide collectively as the "Services"). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This policy (“Privacy Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data. This Privacy Policy is also designed to assist our users who live in the European Union (the “EU”) to understand their applicable data privacy rights that exist under the EU's General Data Protection Regulation when they use the Services. Capitalised terms used in this Privacy Policy that are not otherwise defined have the meanings given to them in the Garena Terms of Service.
1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information.
1.3 By using the Services, registering for an account with us or visiting our Site, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein.
IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR GAMES OR SITE. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on the Site. We reserve the right to amend this Privacy Policy at any time.

2. WHEN WILL GARENA COLLECT PERSONAL DATA?

2.1 We will/may collect personal data about you:
• when you register and/or use our Services, Games or Site, or open an account with us;
• when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
• when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
• when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;
• when you use our electronic services, or interact with us via our Games or Site or use our Services. This includes, without limitation, through cookies which we may deploy when you interact with our Games or Site;
• when you carry out transactions through our Games or Site;
• when you provide us with feedback or complaints;
• when you register for a contest, for games or game specific events;
• during your gameplay; and
• when you submit your personal data to us for any reason.
The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

3. WHAT PERSONAL DATA WILL GARENA COLLECT?

3.1 The personal data that Garena may collect includes but is not limited to:
• name;
• email address;
• date of birth;
• billing address;
• bank account and payment information;
• telephone number;
• gender;
• information sent by or associated with the device(s) used to access our Services;
• any other information about the user when the user signs up to use our Services, and when the user uses the Services, as well as information related to how the user uses our Services; and
• aggregate data on content the user engages with.
3.2 You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inacuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify the information provided by you.
3.3 If you sign up to be a user of our Services using your social media account (“Social Media Account”), link your account to your Social Media Account or use any Garena social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider's policies, and we will manage and use such personal data in accordance with this Privacy Policy at all times.
3.4 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing. Further information on opting out can be found in the section below entitled "How can you withdraw consent, remove, request access to or modify information you have provided to us?". Note, however, that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services. For example, opting out of the collection of location information will cause its location-based features to be disabled.

4. COLLECTION OF OTHER DATA

4.1 As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you use our Services. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our Games and Site.
4.2 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more purposes including, without limitation, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or the device manufacturer.

5. COOKIES

5.1 We may from time to time implement "cookies" or other features to allow us or third parties to collect or share information that will help us improve our Site, Games and the Services we offer, or help us offer new services and features. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your computer or device and tell us how and when the Services or website are used or visited, by how many people and to track activity within our Site and Games. We may link cookie information to personal data. Cookies also link to information regarding what items you have selected for purchase pages you have viewed, or games you have played. This information is used to keep track of your shopping cart, for example. Cookies are also used to deliver content specific to your interest and to monitor usage of the Services.
5.2 You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of our Site, Games or the Services.

6. HOW DO WE USE THE INFORMATION YOU PROVIDE US?

6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
(a) to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;
(b) to manage, operate, provide and/or administer your use of and/or access to our Services, Site and Games (including, without limitation, your preferences), as well as your relationship and user account with us;
(c) to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
(d) to enforce our Terms of Service or any applicable end user license agreements;
(e) to protect personal safety and the rights, property or safety of others;
(f) for identification and/or verification;
(g) to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
(h) to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;
(i) to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(j) to allow other users to interact or connect with you, including to inform you when another user has sent you a private message or posted a comment for you on the Games or Site;
(k) to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience;
(l) to allow for advertising and other audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with Garena’s Services;
(m) for marketing and, in this regard, to send you by various modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom Garena may collaborate or tie up with) that Garena (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies;
(n) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on Garena or on its related corporations or affiliates;
(o) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
(p) to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
(q) to audit our Services or Garena's business;
(r) to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
(s) to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
(t) to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves Garena as a participant or involves only a related corporation or affiliate of Garena as a participant or involves Garena and/or any one or more of Garena's related corporations or affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation; and/or
(u) any other purposes which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”).
6.2 You acknowledge, consent and agree that Garena may access, preserve and disclose your Account information and Content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over Garena or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over Garena, (c) enforce the Garena Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against Garena or other claim that any Content violates the rights of third parties; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of Garena, its users and/or the public.
6.3 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.

7. HOW DOES GARENA PROTECT AND RETAIN CUSTOMER INFORMATION?

7.1 We implement a variety of security measures and strive to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security.
7.2 We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interest warrant further retention of such personal data. If you cease using our Services, or your permission to use the Site, Games and/or the Services is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

8. DOES GARENA DISCLOSE THE INFORMATION IT COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES?

8.1 In conducting our business, we will/may need to disclose your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Such third parties include, without limitation:
• our subsidiaries, affiliates and related corporations;
• other users of our Platform for one or more of the above-stated Purposes;
• contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres;
• a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Garena’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Garena about our users is among the assets transferred; or to a counterparty in a business asset transaction that Garena or any of its affiliates or related corporations is involved in; and
• third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.
8.2 This may require, among other things, disclosing your gaming history and/or disclosing records showing which games were viewed by which IP addresses. We will also share statistical and demographic information about our users and their use of the Services with suppliers of advertisements and programming.
8.3 Additionally, you may elect to export your user activity feeds as RSS feeds which may be subscribed to by other users, which may include information regarding your game play, installation of games, connections with other users and other information about your account activity which is published as a feed on the Site or Games.
8.4 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply.
8.5 Third parties may unlawfully intercept or access personal data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.

9. INFORMATION ON CHILDREN

9.1 The Services are not intended for children under the age of 13. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 13 nor is any part of our Site, Games or other Services directed to children under the age of 13. As a parent or legal guardian, please do not allow such children under your care to submit personal data to Garena. In the event that personal data of a child under the age of 13 in your care is disclosed to Garena, you hereby consent to the processing of the child’s personal data and accept and agree to be bound by this Privacy Policy on behalf of such child. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted without parental consent by any child under the age of 13.
10. INFORMATION COLLECTED BY THIRD PARTIES

10.1 Our Site and Games use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your device, to help the website analyse how users use our Services. The information generated by the cookie about your use of the Services or device (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our Services, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
10.2 We, and third parties, may from time to time make software applications downloads available for your use on or through the Services. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your User ID, your device’s IP Address or other information such as what game you are playing during any given session, and any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by Garena. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.

11. DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES

11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you place orders or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.
11.2 In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Site or Games. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through our Site or Games) may not be received by us.
11.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Site and Games and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).
12. WILL GARENA TRANSFER YOUR INFORMATION OVERSEAS?

12.1 Your personal data and/or information may be transferred to, stored or processed outside of your country. In most cases, your personal data will be processed in Singapore, where our servers are located and our central database is operated. If you are a user in India, your personal data will be processed and stored in our servers in India or Singapore. Garena will only transfer your information overseas in accordance with Privacy Laws. More information about the transfer out of the EU, of personal data and/or information relating to users who are located in the EU, can be found in the section titled "Additional Provisions for EU Users Only".
13. HOW CAN YOU WITHDRAW CONSENT, REQUEST ACCESS TO OR CORRECT INFORMATION YOU HAVE PROVIDED TO US?

Withdrawing Consent
13.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by sending an email to our Personal Data Protection Officer at dpo.sg@garena.com, and we will process such requests in accordance with this Privacy Policy and our obligations under the Privacy Laws and other applicable law.
13.2 However, your withdrawal of consent may mean that we will not be able to continue providing the Services to you, and we may need to terminate your existing relationship and/or the contract you have with us.
Requesting Access to, or Correction of Personal Data
13.3 If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the Account Settings page or tab on the Site or Games. If you do not have an account with us, you may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email to our Personal Data Protection Officer at dpo.sg@garena.com.
13.4 We may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
13.5 We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organisation to refuse to correct personal data in stated circumstances.

14. ADDITIONAL PROVISIONS FOR EU USERS ONLY

14.1 The provisions in this Section only apply if you are a user who is located in the European Union (“EU”). These provisions take precedence over any inconsistent provisions in the remainder of this Privacy Policy.
14.2 Portability
You have the right to obtain from us the Personal Data that you have previously provided to us, and which we process on the basis of your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such Personal Data to another party. If you wish for us to transfer the Personal Data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party. We also may not provide you with certain Personal Data if providing it would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person).
14.3 Erasure
You may request that we erase the Personal Data we hold about you in the following circumstances:
(a) you believe that it is no longer necessary for us to hold the Personal Data we hold about you;
(b) we are processing the Personal Data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the Personal Data;
(c) we are processing the Personal Data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to process and retain such Personal Data;
(d) you no longer wish us to use the Personal Data we hold about you in order to send you promotions, special offers, marketing and lucky draws; or
(e) you believe the Personal Data we hold about you is being unlawfully processed by us.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Personal Data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Please note that after deleting the Personal Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.
14.4 Retention of Personal Data
We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws. If you make a request for erasure of your Personal Data 3 and we determine that there is a valid basis for your request, we will endeavour to erase the Personal Data within 30 days of your request, or inform you if it will take longer.
14.5 Objection against Profiling and Targeted Marketing
At any time you have the right to object to our processing of Personal Data about you in order to send you promotions, special offers and marketing messages, including where we build profiles for such purposes and we will stop processing the Personal Data for that purpose. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for objection. However, we may retain the Personal Data if there are valid grounds under law for us to do so.
14.6 Restriction of Processing to Storage Only
You have a right to request that we restrict the processing of the Personal Data we hold about you to storage purposes only, where:
(a) you believe the Personal Data is not accurate, for the period it takes for us to verify whether the Personal Data is accurate;
(b) we wish to erase the Personal Data but you want us to just store it instead;
(c) we wish to erase the Personal Data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or
(d) you have objected to us processing Personal Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Personal Data whilst we determine whether there is an overriding interest in us processing and retaining such Personal Data.
14.7 Transfer of Personal Data outside the EU
Your Personal Data may be transferred outside of the EU. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as appropriate contractual clauses to ensure that the recipients of such transfer protect and treat your Personal Data in accordance with all applicable personal data protection laws.
14.8 Information on Children
The Services are not intended for children under the age of 16 who are located in the EU. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 16 who is located in the EU, nor is any part of our Site, Games or other Services directed to children under the age of 16 who are located in the EU. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted by any child under the age of 16 who is located in the EU.
15. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US

15.1 If you have any questions, concerns or complaints about our privacy practices, please contact us at dpo.sg@garena.com.
Last modified: 24 September 2020

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