Preliminary remarks:
The developer of TERA, Bluehole Studio, Inc., KRAFTON TOWER, 117 Bundang-gu, Seongnam-si, Gyenggi-do, Korea (“Bluehole”) is hosting the 2021 TERA World Dungeon Challenge. We, Gameforge 4D GmbH, Albert-Nestler-Straße 8, 76131, Karlsruhe, Germany (“Gameforge”), are enabling our TERA players to take part in this “Contest”.
To do so, users interested in participating must obtain a Contest Ticket from the NPC Dundunuk. They can then enter the event dungeon with their dungeon group and try to complete its first stage in the period from 6 AM (UTC) on 13th December 2021 until 2:59 PM (UTC) on 19th December 2021 (“Event Period”). If successful, all members of this group will immediately be entered into the Contest (“Participant”). No further actions are required to participate.
In order to determine the winners, Bluehole will regularly update an overview of the current rankings (“Contest Rankings”) and for this purpose will receive the following “Contest Data” from Gameforge for all Participants on an hourly basis during the event period via encrypted transmission: the respective TERA region (e.g. EU), character name and level, class and group ID, the selected difficulty level, the time needed for a successful run, and the respective time of completion.
Participants automatically provide this Contest Data to Gameforge when they participate. This is done voluntarily and is not mandated by law or contract. If a user interested in participating does not wish to provide this Contest Data, the user in question may at any time refrain from obtaining a Contest Ticket or from entering and completing the event dungeon during the Test/Event Period. It is then not possible to participate in the Contest.
To make sure all the systems are working during the Event Period, there will also be a preparatory test run between 6 AM (UTC) on 6th December 2021 and 2:59 PM (UTC) on 8th December 2021. This Data Protection Information applies accordingly for this “Test Period”.
While Bluehole is responsible for determining the winners, Gameforge ensures the fair running of the Contest. The Standard Terms and Conditions of Use apply as usual while participating in the game. Although Bluehole is the organizer of the Contest, the Conditions for Participation in Competitions and Contests supplement the Contest conditions provided by Bluehole. At the same time, the personal data of Participants from our regions (EU, RU, NA, SEA) are processed while participating in the game and using Gameforge services in accordance with our Privacy Policy , which includes, among other things, the contact details of our data protection officer.
The processing by Bluehole of the Contest Data of Participants from our regions transferred by us is conducted in accordance with the Privacy Policy provided by Bluehole. The compilation of the Contest Data and its transfer to Bluehole shall otherwise be conducted in accordance with the following:
No. 1 (The responsible parties)
Gameforge is responsible for the compilation and transfer of the Contest Data and the subsequent contacting of the winners from our regions determined by Bluehole for the purpose of awarding prizes. Where the respective prize consists of the payment of a cash amount, Gameforge will request the winner’s account information and transfer the prize money on behalf of Bluehole. Where a prize consists of digital content, Gameforge will add this to the account of the respective winner.
Bluehole is solely responsible for determining the winners.
No. 2 (Purposes and legal basis of processing, legitimate interests)
The legal basis for the processing as described above is Article 6(1)(f) GDPR. Gameforge has a legitimate interest in enabling its customers to participate in the Contest, ensuring its orderly implementation (including the awarding of prizes), and, together with Bluehole, promoting its special features. The respective processing is conducted exclusively for the abovementioned purposes.
The transfer of the Contest Data is done in accordance with the provisions of the agreement concluded between Gameforge and Bluehole on the joint processing of Contest Data as well as in accordance with the standard contractual clauses concluded in the same manner (Article 46(2)(c) GDPR).
In accordance with Article 22 GDPR, there will be no automated decision-making in individual cases or profiling.
No. 3 (Recipient of the Contest Data)
Gameforge transfers the Contest Data exclusively to Bluehole. Bluehole will subsequently make part of this data publicly accessible in the Contest Rankings.
No. 4 (Transfer of Contest Data to a third country)
Bluehole is based in the third country South Korea. An adequacy decision (Article 45 GDPR) for this country has not yet been published. However, the EU Commission has initiated a procedure for the adoption of such a decision for South Korea. As this decision has not yet been issued, Gameforge and Bluehole have provided adequate safeguards for this transfer through the use of the standard contractual clauses in their current version. These standard contractual clauses can be viewed on a website provided by the EU Commission.
No. 5 (Storage period)
Bluehole will delete the Contest Data received during the Test Period immediately following the end of this period, and will store the Contest Data received during the Contest Period for the duration of the Contest. Furthermore, Bluehole will retain the Contest Data included in the Contest Rankings following the end of the Contest Period for future reference for the following 12 months.
No. 6 (Data subject rights)
Gameforge is the contact point for all Participants with regard to data subject rights. Where the respective asserted right relates to processing within Gameforge’s scope of responsibility, Gameforge will comply with the respective request as described in the Privacy Policy. Where the respective asserted right lies within Bluehole’s scope of responsibility, Gameforge will forward the request of the Participant in question to Bluehole upon the Participant’s instruction. Alternatively, the Participant may contact Bluehole directly. If a Participant contacts Bluehole and the respective request falls within Gameforge’s scope of responsibility, Bluehole will forward the request to Gameforge accordingly.
Specifically, the following data subject rights apply:
- Data subjects may request information about their personal data processed by the respective responsible party.
- If the relevant requirements are met, data subjects may also request the correction or deletion of this data, or the restriction of its processing, or object to said processing.
- If the conditions for this are met in the individual case, the right to data portability may also exist.
- Data subjects are also entitled to complain to the responsible supervisory authority about the handling of their personal data.
