Privacy Policy

Privacy Policy

Last updated: 2026.07.01

Effective date: 2026.07.01

THUNDER GAMES Co., Ltd. (“Company,” “we,” “us,” or “our”) values the privacy of users who use our services (“User” or “you”). We comply with the Personal Information Protection Act of the Republic of Korea and other applicable privacy and data protection laws, regulations, and guidelines.

This Privacy Policy explains what information we collect, how we use it, how long we retain it, how we disclose or transfer it, how we protect it, and what rights you have regarding your personal information.

This English Privacy Policy is intended for users outside the Republic of Korea. If you use our services in the Republic of Korea, the Korean Privacy Policy shall apply.

This Privacy Policy contains the following sections:

1. Information We Collect

2. Purpose of Collection and Use of Personal Information

3. Retention and Use Period of Personal Information

4. Disclosure, Outsourcing, and International Transfer of Personal Information

5. Destruction of Personal Information

6. Your Rights and How to Exercise Them

7. Cookies, Advertising Identifiers, and Opt-Out

8. Security Measures

9. Children’s Personal Information

10. U.S. and California Privacy Rights

11. Privacy Officer

12. Changes to this Privacy Policy

1. Information We Collect

(1) Game Services

We collect the minimum amount of personal information necessary to provide our services.

- Required information

· Nickname

· Google: Account identifier

· Apple: Account identifier

· Guest: Account identifier

- Information automatically generated or collected during use of the service

· PID, UUID, service usage records including date and time, and location information

· Service usage records and related log files, including timestamps, chat logs, contents exchanged between users such as text, images, videos, and audio, information about the other party to the chat, data transmission time, type and method, and other activities and interactions within the game service

The above information may include both personal information and non-personal information.

- Information that is not personal information but may be automatically generated during use of the service

· Advertising identifier, device information including OS version, app version, language, and country

- Method of collection

· We collect information when users install our mobile application, access the service, use game features, communicate with other users, or otherwise use our services.

- Right to refuse consent and disadvantages resulting from refusal

· You have the right to refuse consent to the collection and use of personal information.

· Refusing optional information will not restrict your use of the service.

· However, if you refuse to provide required information, we may not be able to receive, process, or respond to your customer support request.

(2) Customer Support

When you contact customer support, we may collect the following information:

- Required information: Email address

- Optional information: Name, game nickname, game ID

- Method of collection

· We collect information when you submit an inquiry, request support, or communicate with us in relation to our services.

- Right to refuse consent and disadvantages resulting from refusal

· You have the right to refuse consent to the collection and use of personal information.

· Refusing optional information will not restrict your use of the service.

· However, if you refuse to provide required information, you may not be able to use the service.

(3) Payment Information

We do not directly collect or store your full payment card information or payment method details.

Payments for in-app purchases are processed by the applicable app store or payment service provider, such as Google Play or Apple App Store.

However, we may collect and retain purchase history, payment status, transaction identifiers, receipt information, cancellation records, and refund-related records to provide paid services, process customer support requests, prevent fraud, and comply with applicable laws.

(4) Events, Surveys, and Promotions

If you participate in events, surveys, promotions, or reward programs, we may collect additional information necessary to operate the event or provide rewards.

Such information may include your name, email address, game ID, nickname, delivery information, or other contact information, depending on the nature of the event.

Participation in events, surveys, or promotions is voluntary.

2. Purpose of Collection and Use of Personal Information

We use your personal information for the following purposes:

- To identify users and verify user identity for the services provided by the Company

- To support SNS-based cross-platform account linking

- To receive inquiries, process complaints, provide customer support, and notify users of support results

- To detect, prevent, investigate, and respond to unauthorized or abusive use of the service

- To analyze service operation and improve user experience

- To enable content transmission between users within the service

- To monitor potential violations of laws, regulations, and our Terms of Service

- To provide, maintain, protect, and improve our services

- To provide advertisements, including personalized advertisements, and measure advertising performance

- To manage the relationship between the Company and users and provide services in accordance with our Terms of Service

- To comply with applicable laws, regulations, legal procedures, and enforceable governmental requests

For users in the EU/EEA, the legal bases for processing personal information may include performance of a contract, compliance with legal obligations, legitimate interests such as service security, fraud prevention, service improvement and analytics, and consent where required by law.

3. Retention and Use Period of Personal Information

We destroy personal information without delay once the purpose of collection and use has been achieved. However, we may retain certain information for the following periods where necessary under Company policy or applicable laws.

- Retention under Company policy

· Information collected under Section 1: Until the user withdraws from the service. However, service usage records and related log files may be retained for up to one month after withdrawal.

· Information related to abusive or unauthorized use: For the period necessary to maintain sanctions, prevent repeated abuse, and respond to related disputes.

- Retention under applicable laws

· Records on labeling and advertising: 6 months

· Records on contracts or withdrawal of subscription: 5 years

· Records on payment and supply of goods or services: 5 years

· Electronic transaction records relating to sales, cancellations, refunds, and accounting: 5 years

· Records on consumer complaints or dispute resolution: 3 years

· Service usage records: 3 months

If a longer retention period is required or permitted by applicable law, we may retain the relevant information for that period.

4. Disclosure, Outsourcing, and International Transfer of Personal Information

(1) Outsourcing of Personal Information Processing

We may outsource the processing of personal information to third-party service providers to the extent necessary to provide and operate our services.

In such cases, we take reasonable measures to ensure that personal information is processed securely and in accordance with applicable laws.

Service providers may include cloud service providers, customer support solution providers, analytics providers, advertising partners, payment service providers, and other service operation partners.

(2) Third-Party Disclosure

We do not use your personal information for purposes other than those notified to you, nor do we provide it to third parties without your consent, except in the following cases:

① Where we have obtained separate consent from the user

② Where disclosure is required or permitted by applicable laws, regulations, court orders, or requests from law enforcement or governmental authorities in accordance with lawful procedures

③ Where disclosure is necessary to protect the rights, property, or safety of the Company, users, or others

④ Where information is provided in an aggregated, anonymized, or de-identified form that does not identify individual users

⑤ Where information is transferred in connection with a merger, acquisition, corporate restructuring, sale of assets, financing, or transfer of all or part of our business

(3) International Transfer of Personal Information

To provide and maintain our services smoothly, we may transfer personal information overseas as follows. Except as described below, we do not transfer users’ personal information overseas unless we provide prior notice and obtain separate consent where required by law.

· Recipient of personal information: Google Inc. (Firebase)

· Contact information of the recipient: googlekrsupport@google.com

· Transferred items: PID, UUID, service usage records including date and time, and approximate location information

· Country of transfer: United States

· Date and method of transfer: Transmitted through the network whenever data is updated during use of the service

· Purpose of transfer: Cloud server operation and management

· Retention and use period: Until the user withdraws from the service

If you access our services from outside the Republic of Korea, your information may also be transferred to and processed in the Republic of Korea, where the Company operates its services.

Data protection laws in countries where your information is processed may differ from those in your country. We take reasonable measures to protect your personal information in accordance with this Privacy Policy and applicable laws.

5. Destruction of Personal Information

We destroy personal information without delay once the purpose of collection and use has been achieved or the applicable retention period has expired.

- Destruction procedure

Personal information is destroyed after the purpose of collection and use has been achieved. If the information must be retained under applicable laws or with the user’s consent, it will be stored for the required period and then destroyed.

- Destruction method

Personal information stored in electronic file format is deleted using technical methods that make the records unrecoverable. Personal information stored in paper documents, CDs, or other physical media is destroyed by shredding, incineration, or other secure physical destruction methods.

6. Your Rights and How to Exercise Them

You have the right to determine how your personal information is processed. You may request access to, correction of, or deletion of your personal information at any time.

To exercise your rights, please contact our Privacy Officer by email or phone. After verifying your identity, we will respond without delay in accordance with applicable laws.

If you request correction of an error in your personal information, we will not use or disclose the relevant information until the correction is completed. If incorrect personal information has already been provided to a third party, we will notify the third party of the correction without delay so that the correction can be made.

Personal information deleted or terminated at your request will be processed in accordance with Section 3, “Retention and Use Period of Personal Information,” and will not be used or accessed for other purposes.

(1) EU/EEA Privacy Rights

If you are located in the European Union or European Economic Area, you may have the following rights under applicable data protection laws:

- Right of access: You may request confirmation as to whether we process your personal information and request access to such information.

- Right to rectification: You may request correction of inaccurate or incomplete personal information.

- Right to erasure: You may request deletion of your personal information under certain circumstances.

- Right to restriction of processing: You may request restriction of processing under certain circumstances.

- Right to data portability: You may request to receive your personal information in a structured, commonly used, and machine-readable format where applicable.

- Right to object: You may object to certain processing of your personal information, including processing for direct marketing purposes.

- Right to withdraw consent: Where processing is based on your consent, you may withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

- Right to lodge a complaint: You may lodge a complaint with a competent data protection supervisory authority.

We do not carry out automated decision-making that produces legal effects or similarly significant effects concerning you.

7. Cookies, Advertising Identifiers, and Opt-Out

(1) Advertising Identifiers and Personalized Advertising

We use advertising identifiers to provide users with more suitable and useful services and advertisements, including personalized advertisements.

Advertising identifiers may be automatically collected when the advertising function is enabled in the OS settings of a user’s smartphone or tablet PC. Users may prevent advertising identifiers from being used for interest-based advertising by changing device settings or using the opt-out functions provided by advertising platform providers.

Even if you opt out, non-personalized or general advertisements may still be displayed.

① Marketing analytics tool / advertising platform providers

- Marketing analytics tool: Adjust

- Advertising platform providers: Unity Ads, Google AdMob, Facebook, MoPub, Vungle, AppLovin, TikTok, ironSource, Pangle

② Marketing information opt-out

- Android: Disable marketing information settings in [Settings > Google > Privacy > Marketing Information], where available.

③ Personalized advertising opt-out

- Android: Select “Opt out of Ads Personalization” or similar options in [Settings > Google > Ads] or [Settings > Google > Privacy > Ads].

- iOS: Disable “Personalized Ads” in [Settings > Privacy & Security > Apple Advertising].

④ Advertising platform opt-out links

- Unity Ads: https://unity.com/legal/game-player-and-app-user-privacy-policy

- Google AdMob: https://policies.google.com/privacy

- Facebook / Meta: https://privacycenter.instagram.com/dialog/ads/

- Vungle / Liftoff: https://liftoff.ai/opt-out/

- AppLovin: https://legal.applovin.com/privacy/

- TikTok: https://www.tiktok.com/legal/page/kr/privacy-policy/en

- ironSource: https://cdn.iads.unity3d.com/privacy-policy/privacypolicy.html

- Pangle: https://www.pangleglobal.com/privacy/enduser-en

(2) Cookies and Similar Technologies

We may use cookies and similar technologies on our websites, customer support pages, event pages, or other web-based services connected to our services.

Cookies are small text files stored on your device to help operate services, maintain security, analyze usage, improve user experience, and provide advertisements.

We may use the following types of cookies:

- Required cookies

These cookies are necessary to operate and secure our services. They may be used to detect abuse, prevent fraud, enforce our Terms of Service, and protect users.

- Performance and functional cookies

These cookies help us understand how users use our services, improve service performance, maintain user preferences, and analyze service usage.

- Advertising cookies

These cookies may be used to provide personalized advertisements and measure advertising performance.

Some cookies or similar technologies may be provided by third-party service providers. We do not control the privacy practices of such third parties, and their processing of information is governed by their own privacy policies.

You may refuse or delete cookies through your browser or device settings. However, if you disable certain cookies, some features of the service may not function properly.

(3) Analytics Software Opt-Out

Analytics software may be used to analyze automatically generated information when users visit websites or use mobile services. Users may refuse such tracking through device or browser settings.

- Android: Select “Smart Tracking Prevention,” “Do Not Track,” or similar settings in the privacy and security settings of your device or browser.

- iOS: Disable “Allow Apps to Request to Track” in [Settings > Privacy & Security > Tracking].

- Internet Explorer: Select “Turn on Do Not Track requests” in the browser safety settings.

- Chrome: Select “Send a ‘Do Not Track’ request with your browsing traffic” in [Settings > Privacy and Security > Cookies and other site data].

8. Security Measures

We take the following measures to protect personal information.

(1) Administrative Measures

- Establishment and implementation of an internal management plan

We establish and operate an internal management plan for personal information protection, including the designation of a Privacy Officer and the organization and operation of personal information protection procedures.

- Regular employee training

We limit the number of employees who handle personal information to the minimum necessary and provide training to employees who handle personal information.

(2) Technical Measures

- Access control for personal information processing systems

We manage access rights to database systems and other systems that process personal information and use security measures to prevent unauthorized external access.

- Security programs

We install security programs and conduct regular updates and inspections to prevent leakage or damage of personal information caused by hacking, computer viruses, or other security threats.

(3) Physical Measures

- Secure storage of documents

Documents, USB drives, and other storage media containing personal information are stored in places equipped with locking devices or other security measures.

9. Children’s Personal Information

We do not knowingly collect personal information from children under the age required by applicable law without consent from a parent or legal guardian.

Some of our services may have age restrictions depending on country, region, platform, OS, app store policy, or the nature of the service. If you are under the applicable age restriction, you should not use or attempt to use our services without the consent or supervision of a parent or legal guardian.

If we become aware that we have collected personal information from a child without required parental or legal guardian consent, we will take reasonable steps to delete such information without delay.

If you believe that we may have collected personal information from a child without proper consent, please contact us using the contact information below.

10. U.S. and California Privacy Rights

This section applies to users residing in the United States, including residents of California, to the extent applicable under U.S. state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act.

Depending on your state of residence and applicable law, you may have the following rights regarding your personal information:

- Right to know/access

You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the purposes for collecting, using, disclosing, or sharing the information, and the categories of third parties to whom we disclose or share the information.

- Right to deletion

You may request that we delete personal information we have collected from you, subject to certain exceptions permitted by applicable law.

- Right to correction

You may request that we correct inaccurate personal information that we maintain about you.

- Right to opt out of sale or sharing

We do not sell your personal information for money. However, certain advertising or analytics activities may be considered “sharing” or “sale” under applicable U.S. state privacy laws. Where required by applicable law, you may opt out of the sale or sharing of your personal information, including sharing for cross-context behavioral advertising.

- Right to limit the use and disclosure of sensitive personal information

Where applicable, you may request that we limit the use and disclosure of sensitive personal information to purposes permitted by law.

- Right to opt out of targeted advertising

You may opt out of the processing of your personal information for targeted advertising where required by applicable law. You may also manage personalized advertising through your device settings and the opt-out tools provided by advertising platform providers.

- Right to non-discrimination

We will not discriminate against you for exercising your privacy rights. This means we will not deny services, charge different prices, or provide a different level or quality of service solely because you exercised your privacy rights, except as permitted by applicable law.

To exercise your U.S. or California privacy rights, please contact us at:

Email: help@thundergames.co.kr

Phone: +82-51-742-8772

We may need to verify your identity before processing your request. Verification may require information reasonably necessary to confirm that you are the user whose personal information is the subject of the request.

You may also authorize another person or entity to submit a request on your behalf, where permitted by applicable law. In such cases, we may request proof of authorization and may also require you to verify your identity directly with us.

Do Not Track and Global Privacy Control

Some web browsers or devices may transmit “Do Not Track” signals. Because there is currently no uniform industry standard for responding to Do Not Track signals, we may not respond to such signals.

Where required by applicable law, we will make reasonable efforts to recognize and honor legally required opt-out preference signals, such as Global Privacy Control, if technically feasible and applicable to our services.

Notice of Financial Incentives

We do not currently offer financial incentives or price or service differences in exchange for the collection, retention, sale, or sharing of personal information. If we introduce such programs in the future, we will provide notice and obtain consent where required by applicable law.

11. Privacy Officer

We have designated the following Privacy Officer to protect users’ personal information and handle complaints related to personal information.

- Privacy Officer

· Name: Park Sang-eun

· Department: Development Team

· Email: help@thundergames.co.kr

· Phone: +82-51-742-8772

Users may report privacy-related inquiries, complaints, or requests to the Privacy Officer.

12. Changes to this Privacy Policy

If we make changes to this Privacy Policy, we will notify users at least 7 days before the effective date through our website, in-game notice, or other appropriate methods.

If the changes materially affect users’ rights or obligations, we will notify users at least 30 days before the effective date.

Privacy Policy Version: 2026.07.01

Effective Date: 2026.07.01