GOLF SUPER CREW Privacy Policy
Introduction
TwoHands Games Co., Ltd. (“TwoHands Games,” “Company,” “we,” “us,” or “our”) takes the protection of personal information (“Personal Data”) very seriously. Please read this Privacy Policy (“Policy”) to understand how we collect, use, and protect your Personal Data, and what rights you may have under applicable laws and regulations, including the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).
Our Role in Processing Your Personal Data
Within the scope of this Policy, TwoHands Games acts as a Data Controller under the GDPR or a “Business” under the CCPA. This means that we determine the purposes and means of processing your Personal Data.
Legal Bases for Processing
We must have a valid legal basis to process your Personal Data (“Legal Basis”). We may process your Personal Data on the following grounds:
Legal Obligation: Where processing is necessary to comply with legal obligations.
Legitimate Interests: Where processing is necessary for our legitimate interests, provided that such interests do not override your interests or fundamental rights and freedoms. These interests include:
Product Improvement: Enhancing service features and usability.
User Engagement: Providing updates, new features, and relevant content.
Research and Development: Analyzing trends and improving services using anonymized data.
Marketing and Promotions: Promoting services and offering personalized recommendations.
Security and Fraud Prevention: Protecting users and services from security threats, fraud, and abuse.
Legal Compliance: Complying with applicable laws and regulations across jurisdictions.
Business Operations: Managing daily operations and ensuring service continuity.
When we rely on legitimate interests, you may request further information about our reasoning. Where processing is based on your consent, you may withdraw your consent at any time; however, this will not affect the lawfulness of processing carried out prior to withdrawal.
Categories of Personal Data Collected and Collection Methods
The following categories of Personal Data have been collected by us within the past 12 months:
Category of Personal Data | Collection Method |
Account Information: Authentication tokens from third-party platforms (Google, Apple, Meta) | Collected during third-party authentication for account registration |
In-Game Character Name | Provided directly by the user during game registration and use |
Internet / Network Activity Data: IP address, device ID | Automatically collected during game registration and use |
Mobile Device Information: Device model, operating system, language and country, unique device identifiers, advertising ID | Automatically collected during game registration and use |
Contact Information: Email address | Provided by the user when contacting customer support |
Payment Processing Information (via third-party payment providers): Transaction date and time, transaction ID, product name, amount, marketplace information, email address, phone number, IP address | Collected or provided through third-party payment processors (e.g., Apple, Google) |
Purposes of Use
We may process your Personal Data for the following purposes:
Service Provision: Creating and maintaining accounts, providing and personalizing service features.
Service Improvement: Troubleshooting, data analysis, testing, and improving service quality.
Security: Detecting unauthorized programs, preventing fraud, and addressing security threats.
Customer Support: Responding to user inquiries and support requests.
Event Management: Inviting users to events and managing related communications.
Cookie and Preference Management: Ensuring proper operation of services.
Legal Compliance: Fulfilling record-keeping and other legal obligations.
Dispute Resolution: Enforcing contracts, company policies (including operational policies), and exercising or defending legal claims.
Purchase Processing: Facilitating payments and transactions.
Data Retention
We retain Personal Data only for as long as necessary to fulfill the purposes described above, including compliance with legal, accounting, and reporting requirements. Retention periods are determined based on applicable laws, potential disputes, and the necessity of providing our services.
Sharing and Disclosure of Personal Data
We may share Personal Data in the following circumstances:
Service Providers (Processors): We may engage third-party vendors (e.g., cloud service providers such as Microsoft) to process data on our behalf, strictly in accordance with our instructions.
Third-Party Controllers: We may share data with third-party controllers who process data for their own purposes. Please refer to their respective privacy policies.
Business Transfers: In connection with mergers, acquisitions, asset sales, or similar corporate transactions.
Legal Purposes: When required for law enforcement, governmental authorities, or legal advisors.
With Your Consent: When you have explicitly agreed to such sharing.
Note: Any information you disclose on public forums or message boards may be collected and used by others. Please exercise caution.
International Data Transfers
TwoHands Games is a global company headquartered in the Republic of Korea, and our service providers and partners operate worldwide.
For users in the EEA, the UK, and Switzerland, before transferring Personal Data internationally, we ensure one of the following safeguards is in place:
Obtaining your explicit consent.
Using appropriate safeguards such as EU-approved Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs), or recognized Data Privacy Frameworks.
Transferring data to countries that have received an adequacy decision (such as the Republic of Korea).
Your Rights
You may exercise the following rights in relation to your Personal Data:
Right to Be Informed: Request information about our data processing activities.
Right of Access: Request access to and copies of your Personal Data.
Right to Rectification: Request correction of inaccurate or incomplete data.
Right to Erasure (Right to Be Forgotten): Request deletion of your Personal Data (subject to legal or technical limitations).
Right to Restrict Processing: Request restriction of data processing under certain conditions.
Right to Object: Object to processing based on legitimate interests or to processing for direct marketing purposes.
Right to Data Portability: Request receipt of your data in a machine-readable format or transfer to another controller.
Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.
Right to Non-Discrimination: Not be discriminated against for exercising your rights.
How to Exercise Your Rights
To exercise your rights, please contact us at [email protected]. We will process your request after verifying your identity. If a request is made by an authorized representative, proof of authorization will be required.
Data Security
We implement technical, administrative, and physical security measures—including encryption and anonymization—to protect Personal Data against unauthorized access, disclosure, alteration, or loss.
Complaints to Supervisory Authorities
If you are dissatisfied with our data processing practices, you have the right to lodge a complaint with the data protection authority in your country of residence (e.g., the UK Information Commissioner’s Office).
Changes to This Policy
If this Policy is updated, we will post the revised version on our website and update the “Effective Date.” Continued use of the service after changes become effective constitutes acceptance of the revised Policy.
Contact Information and EU/UK Representatives
TwoHands Games Privacy Team: [email protected]
EU Representative: VeraSafe Netherlands BV (Amsterdam, Netherlands)
UK Representative: VeraSafe United Kingdom Ltd. (London, United Kingdom)
Contact Form: VeraSafe Contact Form