Privacy Policy
Last Effective Date: July 18, 2025
Last Modified Date: June 4, 2025

This Privacy Policy applies to global users (excluding the Republic of Korea) and explains how Bold Play Games Co., Ltd. (“Bold Play Games”) uses the personal data it collects when providing the Black Stigma (“Game”) service.

1. INFORMATION WE COLLECT
Bold Play Games may collect the following data for your use of the Game. Failure to provide any one of the data listed below may result in your inability to use any one of Bold Play Games Game:
  1. Information directly from you: Your personal identification information (name, email address, phone number, date of birth, country of residence, etc.), Steam™ account ID and nickname, region, and in-Game identification information such as user ID, and nickname. You may also need to provide certain personal data, such as Steam™ account ID and nickname for your use of Steam™ Community service (https://steamcommunity.com/).
  2. Information collected automatically: IP address, internet service provider, country code, computer operating system, hardware information, application software, country, game language, chat log, and user’s Game statistics using Google Analytics™ service. Please visit Google’s privacy policy at https://policies.google.com/privacy.
  3. Information collected from third parties: If the Game is distributed and payment is handled by Valve Corporation, its software distribution platform Steam™ may collect Steam™ ID, Profile Image, along with payment information from you. Please review the Steam™ Privacy Policy for more information: https://store.steampowered.com/privacy_agreement/.

2. LEGAL GROUNDS
The legal ground used for our processing activities are:
  1. The processing is necessary for the performance and execution of a contract with you;
  2. The processing is necessary for compliance with legal obligations (including our obligations under applicable tax laws, our legal administration obligations, to cooperate with supervisory authorities);
  3. The processing is necessary for our legitimate (business) interests.
If applicable laws require so, we will process your personal data upon your (explicit) consent. If any kind of processing is based on your consent, we hereby inform you that you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

3. HOW WE USE YOUR INFORMATION
We use the collected information for a variety of purposes, primarily, to provide the Game and the Service to players like you and to improve the quality of the game and service. These include:
  1. Operating and providing the games and services,
  2. Providing opportunities to participate on the events, or surveys that relating to the game(e.g. to deliver goods to players),
  3. Providing customer service by collecting and responding to inquiries,
  4. Sending you newsletters about our game,
  5. Providing advertising information and other information on marketing and promotional events and survey (e.g. offering personalized in-game contents),
  6. Solving technical problems and improving the quality of the game (for example, to provide realistic gaming environment to users),
  7. Identification of individual players to provide the game,
  8. Technical protection against usage of unauthorized programs,
  9. Preventing inappropriate gameplay that could harm other players,
  10. Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity.

4. HOW WE STORE YOUR DATA
Generally, your data will be stored until purpose of collecting such data is achieved. However, Bold Play Games may still store your data if it is required under applicable regulation, law, this privacy policy, or any other related agreement made between you and Bold Play Games. Bold Play Games securely stores your data in accordance with appropriate technical measures. However, due to unforeseen circumstances, Bold Play Games does not guarantee loss, misuse, or alternation of your data by third parties.

5. RETENTION PERIODS
We will not store or keep your personal data for a longer period than is necessary in light of the purposes for which we process them. Only where we are legally obliged to, or where this is necessary for defending our interests in the context of judicial proceedings, we will store the personal data for longer periods.

6. INTERNATIONAL DATA TRANSFERS
Information we collect may be transferred to countries outside your home country for the purposes set out in this Privacy Policy.
You understand that these countries, including Korea, Japan, and the United States, may not provide the same level of data privacy protection as the European Union/European Economic Area or your home country, and you hereby expressly consent to the transfer of your information to these countries for processing in accordance with this Privacy Policy. These transfers are essential to the provision of our Services and performance of the Terms of Service.

7. YOUR DATA PROTECTION RIGHTS
Bold Play Games would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

A. General Rights (All Users)
You have the following rights with respect to your personal data:

Right of Access

    Request confirmation whether we process your data and obtain a copy 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 data, subject to legal obligations or our legitimate interests.
Right to Restrict Processing
    Request that we pause certain processing activities.
Right to Object
    Object to processing based on our legitimate interests or direct marketing.
Right to Data Portability
    Request transfer of data you provided in a structured, commonly used, machine-readable format.
How to Exercise These Rights
    Send your request to help@blackstigma.oqupie.com. We will respond within one month of receipt (extended by up to two additional months, if necessary, with notice).
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B. Additional Rights for EEA Users
If you reside in the European Economic Area, you also have:

Right to Transmission to Another Controller
Request us to transfer your data directly to another provider.
Right to Lodge a Complaint
You may file a complaint with your local Data Protection Authority.

C. California Privacy Rights
If you are a California resident, you additionally have the right to request from us, for the preceding 12-month period:

Categories of Personal Information Disclosed
A description of the categories of data disclosed to third parties for their own direct-marketing purposes.
Identities of Recipients
The names or categories of those third parties.

8. QUESTIONS & COMPLAINTS
For any inquiries, complaints, feedback, or other matters related to personal information protection which arise while you use the Services, please contact the Privacy Protection Officer or the responsible department.
Privacy Protection Officer and Responsible Department
Privacy Protection Officer: Seo Yeol Kim
Contact: Customer Service: help@blackstigma.oqupie.com
We will acknowledge receipt within 5 business days and aim to resolve or update you within 30 days.

9. CHANGES TO THIS POLICY
We may revise this Privacy Policy at any time, and we will update this Policy with any revisions. By continuing to access or use the Services after those changes become effective, you acknowledge and accept that PI will be handled in accordance with the revised Privacy Policy.

A. Revision & Versioning
  1. We maintain a version history. Each update is labeled with a version number (e.g., v1.0, v1.1) and date.
B. Notification of Changes
Substantial changes will be notified at least 30 days before they become effective via:
  1. Email to registered users.
  2. Notice on our website’s privacy policy page.
C. Effective Date
  1. The effective date of the current policy is displayed at the top of this document.