REMEMENTO - WHITE SHADOW
Global Privacy Policy

 

BLACKSTORM Inc. (“Company,” “we,” “us”) is committed to protecting your privacy and handling your data with transparency and respect.
This Privacy Policy explains how we collect, use, and protect your personal information when you use our global game service Rememento: White Shadow.

We comply with international data protection laws including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable privacy regulations.

 

 

1. Information We Collect

We may collect the following categories of personal data:

  • Account Information: Email address, nickname, encrypted password

     
  • Social Logins: Google, Apple account identifiers

     
  • Gameplay & Device Info: IP address, device type, OS, language settings, in-game actions

     
  • Payments: Transaction ID, platform ID, purchase history, currency, country

     
  • Support Requests: Email address, inquiry content

     
  • Tracking Data: Cookies, browser type, usage logs, device identifiers

     

We do not knowingly collect data from children under 16. If we become aware of such a collection, we will delete it immediately.

 

 

2. Purpose of Data Use

Your data is used only for:

  • Account setup and management

     
  • Providing and improving game services

     
  • Processing payments and refunds

     
  • Responding to support inquiries

     
  • Detecting fraud and rule violations

     
  • Conducting analytics and diagnostics

     
  • Marketing communications (only with consent)

     

 

 

3. Data Retention

We retain personal data only as long as necessary for the purposes stated above. The specific durations are as follows:

Data Category

Retention Period

Purpose

Account Information

30 days after account deletion

Prevent account abuse or fraud

Payment & Refund Records

5 years

Financial compliance and dispute resolution

Customer Support Logs

3 years

Service improvement and audit tracking

Access Logs (IP, device info)

6 months

Security monitoring and abuse prevention

 

 

4. Sharing of Personal Information

We do not sell or share your data with third parties unless:

  • You provide explicit consent

     
  • Required by applicable laws or legal processes

     
  • Needed to protect vital interests (fraud, security, safety)

     
  • Provided in anonymized, statistical form

     

 

 

5. International Data Transfers

Your information may be transferred to and stored in countries outside your residence, such as South Korea, the United States, or Singapore. We ensure that all cross-border transfers comply with applicable laws and offer adequate safeguards including:

  • Standard Contractual Clauses (SCCs)

     
  • Data Processing Agreements (DPAs)

     
  • Privacy certifications or lawful frameworks (where applicable)

     

Processor

Location

Data Transferred

Purpose

Xsolla Inc.

United States

Email, payment info, IP, country

Payment processing, refund handling

Amazon Web Services

United States

Game logs, server data

Cloud infrastructure & hosting

Zendesk

United States / Singapore

Support tickets, contact info

Customer support operations

 

 

6. Automated Decision-Making

We do not use your data for automated decisions that legally or significantly affect you (e.g., profiling, auto-bans, or match results).
Any recommendation systems (e.g., friend suggestions) are purely optional and not used for enforcement.

 

 

7. Your Rights

Depending on your country of residence (especially EU/EEA), you may have the following rights:

  • Access to your personal data

     
  • Correction of incorrect or outdated data

     
  • Deletion (right to be forgotten)

     
  • Restriction or objection to processing

     
  • Withdraw marketing consent at any time

     
  • Data Portability: receive your data in a machine-readable format upon request

     

To exercise your rights, contact:
Email: rememento_cs@blackstormcompany.com

 

 

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Analyze site usage and improve performance

     
  • Enable core features (login persistence, language selection)

     
  • Deliver personalized offers (only if you consent)

     

You can manage or disable cookies in your browser settings.
Note: some features may not function properly if cookies are disabled.

 

 

9. Children’s Privacy

Our Service is not intended for individuals under the age of 16.
If we discover that we have unintentionally collected personal data from a child, we will take immediate steps to delete the data.

 

 

10. Data Security

We implement strong security safeguards including:

  • Data encryption in transit and at rest

     
  • Role-based access and strict password policies

     
  • Firewalls and threat monitoring systems

     
  • Regular employee training on data protection

     
  • Scheduled audits and risk assessments

     

 

 

11. Language and Interpretation

This Privacy Policy may be translated into multiple languages for reference.
However, the English version shall prevail in the event of discrepancies or legal interpretation.

 

 

12. Updates to this Policy

We may revise this Policy as our services evolve or as laws change.
You will be notified in advance of any material changes via our website or in-game notices.

 

 

13. Contact Us

Data Protection Officer: Sujin Yang
Email: privacy@blackstormcompany.com
Call: +82-70-8633-0105

Last updated: May 28, 2025

Annex A 

Additional Terms for Residents of the European Economic Area (EEA) 
and the United Kingdom (UK)

If you are a resident of a country in the European Economic Area (EEA) or the United Kingdom, the following additional terms apply to the processing of your personal data under the General Data Protection Regulation (GDPR) and the UK GDPR.

 

 

1. Legal Basis for Processing

We rely on the following legal grounds to process your personal data:

  • Consent: You have given explicit permission for the processing (e.g., email marketing)

     
  • Contract performance: Processing is necessary to fulfill our agreement with you (e.g., to provide the game or process payments)

     
  • Legal obligations: Processing is required to comply with applicable laws

     
  • Legitimate interests: For purposes such as fraud prevention, service improvement, or internal analytics

     

You have the right to object to processing based on legitimate interest at any time.

 

 

2. Your Rights under GDPR

Under GDPR (EU and UK versions), you have the right to:

  • Access your personal data and receive a copy (Art. 15)

     
  • Correct inaccurate or incomplete data (Art. 16)

     
  • Request erasure of your data in certain cases (Art. 17)

     
  • Object to processing based on legitimate interests (Art. 21)

     
  • Restrict processing of your data temporarily (Art. 18)

     
  • Withdraw consent at any time (Art. 7)

     
  • Receive your data in a portable format (Art. 20 – right to data portability)

     
  • Lodge a complaint with your local Data Protection Authority (Art. 77)

     

 

 

3. International Transfers

Your data may be transferred outside of the EEA/UK to countries such as South Korea or the United States.
We ensure such transfers are lawful by using:

  • Standard Contractual Clauses (SCCs) adopted by the European Commission or UK ICO

     
  • Data Processing Agreements with all service providers (e.g., Xsolla, AWS)

     

You may request a copy of these safeguards by contacting us.

 

 

4. Supervisory Authority Contact

You have the right to lodge a complaint with your local data protection authority.
A list of national authorities in the EEA is available here:
- Official Link: https://edpb.europa.eu/about-edpb/board/members_en

For the UK, you may contact the Information Commissioner’s Office (ICO):
- Official Link: https://ico.org.uk/

 

 

 

 

 

 

 

 

 

Annex B 

Additional Terms for Residents of California (CCPA/CPRA)

If you reside in California, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

1. Categories of Personal Information Collected

We collect the following categories of personal information:

  • Identifiers (e.g., email address, IP address, account ID)

     
  • Commercial information (e.g., purchase history)

     
  • Internet activity (e.g., gameplay logs, browser type)

     
  • Device information (e.g., OS, device model)

     

We do not sell your personal data as defined under CCPA.

2. Your Rights Under CCPA/CPRA

As a California resident, you have the right to:

  • Know what personal information we collect, use, and share

     
  • Access and request a copy of your personal information

     
  • Delete personal information we have collected from you

     
  • Correct inaccurate personal information

     
  • Opt out of sale or sharing (not applicable as we do not sell data)

     
  • Limit the use of sensitive personal information (we do not collect sensitive categories)

     

To exercise your rights, please email:
Email: rememento_cs@blackstormcompany.com

You may also designate an authorized agent to act on your behalf.

 

 

Annex C

Additional Terms for Residents of Singapore (PDPA)

If you are a resident of Singapore, we process your personal data in accordance with the Personal Data Protection Act (PDPA) of Singapore.

1. Consent-Based Processing

  • We only collect, use, and disclose your personal data with your consent, or where otherwise permitted or required by law.
  • You may withdraw your consent at any time by contacting us.

     

2. Use of National ID (NRIC) or Similar Identifiers

  • We do not collect NRIC numbers, FIN, passport numbers, or other sensitive identifiers, in accordance with PDPC guidelines.

     

3. Retention & Deletion

  • Personal data will not be retained longer than necessary for the purposes for which it was collected.

     

For data access or correction requests, contact:
Email: rememento_cs@blackstormcompany.com