DEVILS Privacy Policy
Level99 Co., Ltd. (hereinafter referred to as the 'Company') values users' personal information and, to protect users' rights, complies with the 「Personal Information Protection Act」 and other relevant laws, processes personal information lawfully, and manages it securely. In accordance with Article 30 of the 「Personal Information Protection Act」, this Privacy Policy explains how personal information is processed, including its collection, use, provision and destruction, the measures taken to protect users' personal information, and how users can exercise their rights.
This Privacy Policy applies to the mobile game 「DEVILS」 (hereinafter referred to as the 'Game'), which the Company sells as a paid app through Google Play.
Summary
① The Game is used without membership registration or any account managed by the Company, and the Company does not operate game servers. Game data such as characters, items and progress is stored only on the user's device.② The personal information processed by the Company is limited to error analysis information, usage statistics (only if the user consents), and information related to inquiries and refunds sent by the user.
③ Error analysis and usage statistics are processed through Google LLC's Firebase services, in the United States and other countries outside Korea (Article 6).
④ The Company does not collect names, phone numbers, payment method information, precise location information or advertising IDs, and does not provide personal information to third parties or use it for advertising.
Article 1. Purpose of Processing Personal Information
1. The Company processes personal information for the following purposes. Personal information being processed will not be used for purposes other than the following, and if the purpose of use is changed, necessary measures such as obtaining separate consent in accordance with Article 18 of the 「Personal Information Protection Act」 will be implemented.① Proper provision of the purchased Game: analyzing and fixing the causes of errors (such as app crashes), checking operation on different devices and operating systems, and otherwise stabilizing the service
② Analysis of usage statistics to improve the service (only if the user has chosen to consent)
③ Responding to user inquiries, processing withdrawals of purchase offers and refunds for paid purchases, and handling disputes
④ Fulfilling obligations under relevant laws
2. The Company does not display advertisements in the Game and does not use personal information for targeted advertising or marketing.
Article 2. Period of Processing and Retention of Personal Information
1. The Company processes and retains personal information within the retention and use period stipulated by law or the retention and use period agreed to by the user at the time of collection.① Error analysis information: 90 days from collection (automatically deleted by Firebase Crashlytics after the retention period)
② Usage statistics: 2 months from collection (automatically deleted according to the Google Analytics data retention setting). If the user withdraws consent, collection stops from that point.
③ Information for handling inquiries and refunds: destroyed without delay after the inquiry has been handled, except for records falling under ④, which are kept for the applicable period.
④ Retention of personal information according to relevant laws and regulations
- Act on Consumer Protection in Electronic Commerce, etc.
1) Records on contracts or withdrawal of offers, etc.: 5 years
2) Records on payment and supply of goods, etc.: 5 years
3) Records on consumer complaints or dispute resolution: 3 years
Article 3. Items of Personal Information Processed
1. The Company processes the following items of personal information.| Category | Items processed | Method of collection |
|---|---|---|
| ① Error analysis (necessary to provide the Game) | Error records when an error occurs (stack traces and information extracted from native crash dumps), app and device state at the time of the error (memory, storage, screen orientation, whether the device is rooted, etc.), device model, operating system version, app version, Crashlytics installation identifier (UUID), Firebase installation ID, and (if the user has consented to usage statistics) app usage records immediately before the error | Sent automatically by Firebase Crashlytics, included in the Game, when an error occurs while the Game is running |
| ② Usage statistics (optional consent) | App instance ID, app usage records (automatically collected events such as first launch, launches and sessions, and time spent), device model, operating system version, language setting, app version, installation source (whether installed from Google Play, install referral information), and approximate location (country or region estimated after the IP address is masked) | Sent automatically by Google Analytics for Firebase while the Game is used, if the user has consented |
| ③ Handling inquiries and refunds | Email address, content of the inquiry, attachments sent by the user (device model, operating system version, screenshots, etc.), and (for refund or payment inquiries) Google Play order number, purchase date and time, product name, and payment amount and status | Information sent by the user by email, and order information the Company looks up in the Google Play Console to process refunds |
Article 4. Information Not Collected by the Company (Information Stored on the User's Device and Google Account)
1. Game data: Game data (saves) such as characters, items and progress is stored only on the user's device and is not sent to the Company. Because the Company does not operate game servers, it cannot store, view or restore users' game data.2. Cloud save: If the user is signed in to Google Play Games, at regular intervals during play, or when the user selects 'Back up data' in the Game's settings, the game data and a summary of it (character level, main quest progress, play time, and an image of the game screen at the time of saving) are saved to the user's own Google account (Google Play Games 'Saved Games'). This information is processed by Google LLC as a service it provides directly to the user, in accordance with Google's privacy policy; it is not sent to the Company's servers, and the Company does not view it. Saved game data can be deleted in the settings of the Google Play Games app.
3. Google Play Games sign-in: Sign-in and the processing of Google account information are handled by Google LLC, and the Company does not receive the user's Google account information (email address, name, etc.).
4. Payment: Payment for purchasing the Game is processed by Google Play, and the Company does not receive payment method information. The order information the Company looks up to process refunds is as described in Article 3.
5. Device backup: If backup is turned on in the user's device settings, game data may be included in the device backup in the user's Google account through a feature of the Android operating system. This backup is processed by Google, and the Company does not view it.
6. Third-party services linked from the Game or from this document, such as Google Play, are governed by the privacy policies of their respective providers.
Article 5. Matters Concerning Provision of Personal Information to Third Parties
1. The Company processes the user's personal information only within the scope specified in the purpose of processing personal information, and provides personal information to third parties only in cases falling under Articles 17 and 18 of the 「Personal Information Protection Act」, such as user consent or special provisions of the law, and does not provide the user's personal information to third parties otherwise.Article 6. Matters Concerning Entrustment of Personal Information Processing and Cross-Border Transfer
1. The Company directly handles customer support and refund processing and does not outsource these tasks to external service providers.2. The Company entrusts personal information processing for error analysis, usage statistics analysis and receiving email inquiries as follows.
| Entrusted Service Provider | Entrusted Tasks |
|---|---|
| Google LLC | Error analysis (Firebase Crashlytics), usage statistics analysis (Google Analytics for Firebase), receiving and storing email inquiries (Gmail) |
| Recipient (contact) | Google LLC 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA Privacy inquiries: googlekrsupport@google.com |
| Destination countries | The United States and other countries where Google data centers are located |
| Time and method of transfer | While the Game is used or when an error occurs, and when emails are exchanged; encrypted transmission over information and communications networks |
| Items transferred | ① error analysis information, ② usage statistics (if consented), and the inquiry information received by email under ③, as listed in Article 3 |
| Purpose of transfer | Error analysis, usage statistics analysis, and receiving and storing email inquiries |
| Retention and use period | As set out in Article 2 (error analysis information: 90 days; usage statistics: 2 months; inquiry information: destroyed after the inquiry is handled, except records that must be kept by law for the applicable period) |
| How to refuse and effect of refusal | · Usage statistics: If the user does not consent, or withdraws consent in the Game's settings, the information is not sent, and there is no effect on use of the Game. · Error analysis: This is processing necessary to properly provide the purchased Game and is carried out without separate consent (Article 15(1)4 and Article 28-8(1)3 of the 「Personal Information Protection Act」). The user may request the Chief Privacy Officer to suspend the processing, and the Company will handle the request in accordance with relevant laws. · Email inquiries: No transfer takes place unless the user sends an inquiry by email. |
5. Any changes to the entrusted tasks, the service provider, or matters concerning cross-border transfer will be disclosed without delay through this Privacy Policy, and consent will be obtained again where required by law.
Article 7. Matters Concerning Procedures and Methods for Destruction of Personal Information
1. The Company destroys personal information without delay when it is no longer needed, such as when the retention period has expired or the purpose of processing has been achieved.2. If personal information must continue to be retained under other laws even though the retention period agreed to by the user has expired or the purpose of processing has been achieved, the Company keeps it separately. (See 'Period of Processing and Retention of Personal Information')
3. The procedures and methods for destroying personal information are as follows.
① Error analysis information and usage statistics are deleted automatically under Firebase's retention policies once the retention periods in Article 2 have passed.
② Information for handling inquiries and refunds in the form of electronic files is deleted so that the records cannot be restored, and personal information recorded on paper is destroyed by shredding or incineration.
Article 8. Matters Concerning the Rights of Users and Legal Representatives and How to Exercise Them
1. Users may at any time exercise their rights against the Company to request access to, correction of, deletion of, or suspension of processing of their personal information, and to withdraw consent.*Requests for access, etc. regarding the personal information of children under the age of 14 must be made directly by their legal representative. Users who are minors aged 14 or older may exercise rights regarding their personal information themselves or through their legal representative. Where the Company processes the personal information of children under 14 on the basis of consent, it obtains the consent of their legal representative.
2. To exercise your rights, please contact the Chief Privacy Officer in writing or by email (official.lv99@gmail.com), and we will take action without delay. However, the Company may refuse requests for access or correction of all or part of a user's personal information if there is a legitimate reason, in which case the Company will notify the user of the refusal and explain the reason.
3. Because error analysis information and usage statistics are stored under device-level identifiers rather than names or contact details, the Company handles such requests to the extent that it can identify the relevant records from the information provided by the user.
4. Users may also exercise their rights directly in the following ways.
① Withdrawing consent to usage statistics: turn off usage statistics collection in the Game's settings
② Deleting cloud save data: the settings of the Google Play Games app
③ Deleting game data stored on the device: uninstall the Game, or go to [Settings] > [Apps] > [DEVILS] > [Storage] > [Clear data] on the device
5. Requests for deletion may be restricted for personal information that other laws specify as subject to collection. Such restrictions do not limit the right to request correction of inaccurate personal information.
Article 9. Matters Concerning Measures to Ensure the Security of Personal Information
1. The Company takes the following measures to ensure the security of personal information.① Administrative measures: designation of a Chief Privacy Officer, and minimizing, managing and supervising the personnel who handle personal information
② Technical measures: managing access rights to personal information processing systems such as the Firebase console and the Google Play Console with two-step verification, and encrypting data in transit (TLS)
③ Physical measures: controlling access to work devices and materials that handle personal information
Article 10. Matters Concerning the Installation, Operation and Refusal of Devices that Automatically Collect Personal Information
1. The Game does not use cookies.2. For the error analysis and usage statistics described in Article 3, Firebase, which is included in the Game, generates device-level identifiers such as the app instance ID, the Firebase installation ID and the Crashlytics installation identifier and stores them on the device. The Game does not collect the advertising ID.
3. Users can turn off usage statistics collection as described in Article 8(4), and the identifiers stored on the device are deleted when the Game is uninstalled. Turning off usage statistics does not affect use of the Game.
Article 11. Matters Concerning the Chief Privacy Officer and Requests for Access to Personal Information
1. The Company designates a Chief Privacy Officer to oversee and take responsibility for tasks related to personal information processing, and to handle user complaints and provide remedies related to personal information processing.2. Users may submit requests for access to personal information under Article 35 of the 「Personal Information Protection Act」 to the person below. The Company will endeavor to process such requests promptly.
① Chief Privacy Officer / Request for Access
- Name: younwoo chu
- Email: official.lv99@gmail.com
3. Users can contact the Chief Privacy Officer about any inquiries, complaints, damage relief and other matters related to personal information protection that arise while using the Game. The Company will respond to and handle users' inquiries without delay.
Article 12. Remedies for Infringement of Users' Rights and Interests
1. To obtain relief from infringement of personal information, users may apply for dispute resolution or consultation to the Personal Information Dispute Mediation Committee, the Korea Internet & Security Agency (KISA) Personal Information Infringement Report Center, and others. For other reports of and consultations on personal information infringement, please contact the organizations below.① Personal Information Dispute Mediation Committee: (without area code) 1833-6972 (www.kopico.go.kr/)
② Personal Information Infringement Report Center: (without area code) 118 (https://privacy.kisa.or.kr/)
③ Supreme Prosecutors' Office: (without area code) 1301 (https://www.spo.go.kr/)
④ Korean National Police Agency: (without area code) 182 (https://ecrm.police.go.kr/)
2. The Company guarantees users' right to control their own personal information and strives to provide consultation and relief for damage caused by personal information infringement. If you need to make a report or consult, please contact the person below.
① Customer consultation and reports related to personal information protection
- Contact: Chief Privacy Officer
- Email: official.lv99@gmail.com
Article 13. Matters Concerning Changes to the Privacy Policy
1. This Privacy Policy applies from July 20, 2026.2. If any content of this Privacy Policy is added, deleted or modified, the Company will announce it on the Company's website and through notices in the Game, starting 7 days before it takes effect (30 days before, in the case of a material change to users' rights).
3. In case of any discrepancy between the Korean and English versions of this Privacy Policy, the Korean version prevails.
4. [View Consent to Collection, Use and Cross-Border Transfer of Usage Statistics (Optional)] · [View Terms of Service]