PRIVACY NOTICE

Effective Date: [insert date of posting]   TABLE OF CONTENTS

1. 1.INFORMATION WE COLLECT
2. 2.USE OF INFORMATION WE COLLECT / LEGAL BASES FOR PROCESSING
3. 3.DISCLOSURE OF YOUR INFORMATION
4. 4.INTERNATIONAL DATA TRANSFERS
5. 5.DATA RETENTION
6. 6.YOUR RIGHTS AND CHOICES
7. 7.CHANGES TO THIS PRIVACY NOTICE
8. 8.INFORMATION FOR KOREA RESIDENTS
9. 9.CONTACT US

LEGAL INFORMATION

This Privacy Notice describes how Shattershock Limited (“Shattershock”, “we”, “us”, or “our”) collects, uses, discloses or otherwise processes information about users of the website from which this Privacy Notice is being accessed (the “Site”).

By using or interacting with the Site, you (the “User”, “you”, or “your”) understand that we process your information as described in this Privacy Notice.

For purposes of applicable law, Shattershock Limited (an Irish company) is the “Data Controller” of information collected through the Site. Our mailing address is Shattershock Limited, 1st Floor, The Liffey Trust Centre, 117-26 Sheriff Street, Upper, Dublin 1, Ireland, D01 YC43.

1.INFORMATION WE COLLECT

When you use the Site, we collect personal information about you or your use of the Site. The categories of information we collect are:

• • Information You Provide.We collect information that you provide to us directly when you fill out a formon the Site (such as “Contact Us” or “Subscribe”) or send us an email or postal mail. This may include your name, email address, and your message to us.
• • Information We Collect Automatically.

• • Cookies.We collect information through cookies and similar technologies (“Cookies”) to operate and provide the Site.For more details about our use of Cookies, including third-party Cookies, please see our Cookie Notice.

• • Usage Information.We collect information about how the Site is used, including information about Site pages viewed, date/time stamps of actions taken, log files, crash or diagnostic data, performance logs, and error reports or messages.
• • Technical and Network Information.We collect information about the device, browser, and network used to access the Site, such as browser type, hardware model, unique device identifier, operating system, Internet Service Provider, and language and time zone data.
• • General Location.We use IP addresses to estimate your general location, like city and country.

2.USE OF INFORMATION WE COLLECT / LEGAL BASES FOR PROCESSING

Under applicable data protection laws (such as the General Data Protection Regulation), companies must have a legal basis to process your personal data. Below, we describe our legal bases and purposes for processing the information we collect.

• • Processing necessary to perform our contract with you.We process your information as necessary to provide and operate the Site. Specifically, we analyze Information You Provide and Information We Collect Automatically (“Your Information”) to:
  •       ◦ Identify, troubleshoot, and resolve technical errors or issues and monitor Site performance.
  •       ◦ Ensure the safety, security, and integrity of the Site to detect, prevent, and combat behavior that threatens the security of our users’ information or the Site.
  •       ◦ Transfer, store, or process your information outside the European Economic Area (“EEA”), the United Kingdom (“UK”), and/or Switzerland.
• • Legitimate interests.We process your information where the information is necessary for our legitimate interests or the legitimate interests of others (such as those of our users). We process Your Information to:
  •       ◦ Operate, troubleshoot, and improve the Site and our business.
  •       ◦ Promote safety, security, and integrity outside of the performance of our contract with you.
  •       ◦ Understand our users and how they interact with the Site.
  •       ◦ Perform internal analytics concerning the Site.
  •       ◦ Comply with legal requirements or defend our legal rights.

In certain jurisdictions, you have the right to object to, and seek restriction of, this processing based on legitimate interest. To exercise the rights, visit Section 6 of this Privacy Notice.

• • Fulfillment of a legal obligation.We may be required to use Your Information to comply with a legal obligation, such as when we need to respond to a valid legal request.
• • In some cases, we may ask for your consent to use Your Informationfor specific purposes. In these cases, we’ll provide the ability to withdraw your consent.

3.DISCLOSURE OF YOUR INFORMATION

We share your information with others as described below:

• • Service providers.We share Your Information with our service providers who provide web hosting, analytics, and communications services to us.
• • Related companies.We may share Information You Provide with our subsidiaries and affiliates for purposes consistent with this Privacy Notice.
• • Business transfers.In the event we are involved in a corporate sale, merger, reorganization, dissolution, or similar event, or due diligence related to such event, Your Information may be part of the transferred assets.
• • Legal requirements and harm prevention. We may disclose Your Information to comply with a legal obligation or to protect and defend our rights and our users’ rights.

We have not “sold” or “shared” (as those terms are defined by applicable law) personal information in the past 12 months, nor do we “sell” or “share” any personal information about individuals, including those that we know are under sixteen (16) years old. We do not share your personal information with third parties for direct marketing purposes.

4.INTERNATIONAL DATA TRANSFERS

Your personal information is hosted on servers located in the country where you reside. Our service providers, affiliates and subsidiaries, and partners are located in various countries around the world. Your personal information may be transferred to, and processed in, these countries, which may be different from the territory in which you reside. These countries may have data protection laws that are different from those of your jurisdiction (and, in some cases, may not be as protective). These entities commit to processing information in compliance with applicable data protection laws and to implementing appropriate security measures to protect your information.

Where this will involve transferring your personal information outside the UK, EEA and/or Switzerland, we implement the following safeguards to ensure a similar degree of protection is afforded:

• • Adequacy Decisions: We rely on the adequacy decisions to transfer data to Canada, Japan, and the UK (the full list of adequate countries is available herefor the EEA, here for the UK, and here for Switzerland).
• • Standard Contractual Clauses: We rely on the standard contractual clauses issued by the European Commissionand the UK for transfers to countries which are not considered adequate, such as Singapore and Hong Kong. You may obtain a copy of these measures by contacting us.

5. DATA RETENTION

We retain personal information in accordance with our data retention policy and where reasonably necessary to carry out the purposes described in this Privacy Notice. To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; whether we can attain our objectives by other means; and compliance with our legal, regulatory, tax, accounting and other applicable obligations.

6. YOUR RIGHTS AND CHOICES

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, and may apply only in certain circumstances.

• • Request access to or a copy of your personal information.
• • Delete your personal information.
• • Correct or update your personal information where it’s inaccurate.
• • Object to processing of your personal information or ask us to restrict processing of your personal information.
• • Where applicable, withdraw your consent without affecting the processing already undertaken before your withdrawal or the processing of your personal information on other lawful grounds.
• • Complain to a data protection authority about our processing of your personal information. You can file a claim with the Data Protection Authority in the EEA country in which you live or work or where you think we have infringed data protection laws, or with the UK Information Commissioner’s Office, as applicable to you. Contact details for Data Protection Authorities in the EEA are available hereand the UK ICO can be contacted here.
• • Designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf.

You may submit a request to exercise your privacy rights to us at privacy@oc.netease.com or at Shattershock Limited, Attention: Privacy, 1st Floor, The Liffey Trust Centre, 117-26 Sheriff Street, Upper, Dublin 1, Ireland, D01 YC43. We will not discriminate against you for exercising any of these rights. Further information may be needed to verify your identity before these rights can be exercised. If we deny your request, you may appeal our decision by contacting us.

7. CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice from time to time with an updated effective date at the top of this page. By continuing to use the Site, you are confirming that you have read and understood the latest version of this Privacy Notice.

8. INFORMATION FOR KOREA RESIDENTS

This Section applies only if you are a resident of South Korea.

Data sharing. We delegate the processing of your personal information as described below, and the delegates may process your personal data for the below purposes.

Delegatee	Delegated Tasks
Google LLC	Data processor: Processes and stores information on our behalf for website analytics purposes. Please see our Cookie Notice ([insert Cookie Notice URL]).

Data transfers. We provide personal information to third parties overseas as described below.

Name of Recipient (country, contact info)	Overseas Country	Date & Method of Transfer	Items of Personal Information provided	Purpose of Use by Recipient	Period of Retention and Use by Recipient
Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA	USA	Transmitted from time to time	All personal information specified in Section 2	Storage of data and providing analytics services to data controller	See Section ‎5

 

Data destruction. We are required to retain certain personal information for the time periods and pursuant to the laws set forth below.

 

Applicable Law	Types of Personal Information and Retention Period
Republic of Korea: Protection of Communications Secrets Act	Log records and IP address: 3 months
	The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use: 12 months
Republic of Korea: Act on the Consumer Protection in Electronic Commerce	Records regarding customer service or dispute resolution: 3 years
	Records regarding execution or withdrawal of a contract: 5 years

9. CONTACT US

If you have any questions about this Privacy Notice, please contact us at privacy@oc.netease.com or Shattershock Limited, Attention: Privacy, 1st Floor, The Liffey Trust Centre, 117-26 Sheriff Street, Upper, Dublin 1, Ireland, D01 YC43.