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Privacy Policy

Last Updated: May 3, 2026

NGU Studio (hereinafter the "Company") values the personal information of its users and complies with applicable laws including the Personal Information Protection Act of the Republic of Korea and the European Union's General Data Protection Regulation (GDPR). This Privacy Policy applies to the mobile game services (the "Services") and related websites provided by the Company.

1. Data Controller and Contact Information

The Company is the data Controller responsible for processing your personal information. You may reach us using the contact details below.

NGU Studio

CEO: Park Kyung-Min

Address: 1103-2504, 44-7 Saeteo-ro, Gwangmyeong-si, Gyeonggi-do, Republic of Korea

Email: ngustudio2020@gmail.com

2. Categories of Personal Information Collected and How We Collect It

The Company collects only the minimum personal information necessary to provide the Services.

(1) Automatically Collected Items (collected automatically via Google Firebase SDK, AppsFlyer SDK, AppLovin SDK, etc.)

  • Device identifiers: advertising identifiers (ADID, IDFA), device model, OS version, device language and country
  • Connection information: IP address, access timestamps, service usage records, download history, error logs

(2) Information Provided by the User

  • Customer support inquiries: email address, contents of the inquiry
  • In-app purchases: receipt number, purchase history (payment method information is processed directly by the platform store and is not collected by the Company)

3. Purposes of Processing and Legal Bases (GDPR Art. 6)

The Company processes personal information on the following legal bases:

  • Performance of a contract (Art. 6(1)(b)): providing the game services, maintaining and managing game data, processing payments
  • Legitimate interests (Art. 6(1)(f)): service optimization, fraud prevention, statistical analysis
  • User consent (Art. 6(1)(a)): personalized advertising, marketing communications
  • Legal obligation (Art. 6(1)(c)): retention of transaction records as required by tax and e-commerce laws

4. Sharing and Processors

The Company may share personal information with, or entrust its processing to, the following third parties for the operation, analytics, and advertising of the Services:

  • Google LLC (Firebase): game usage analytics, log storage, crash reporting
  • AppLovin Corp.: personalized advertising and performance measurement
  • AppsFlyer Ltd.: marketing attribution and campaign performance measurement

The processing period continues as long as the relevant processing agreement is in effect or until the user withdraws from the Services.

5. Advertising and Tracking

The Company may use advertising identifiers (IDFA, ADID) to deliver personalized advertising. Such advertising is served through advertising partners including AppLovin and AppsFlyer.

You can limit advertising tracking using the following methods:

  • iOS: On iOS 14.5 or later, you can choose whether to allow tracking via the App Tracking Transparency (ATT) prompt shown when launching the app. You can change your choice at any time under [Settings > Privacy & Security > Tracking].
  • Android: Reset your advertising identifier or opt out of personalized ads under [Settings > Google > Ads].
  • EU users: You may withdraw your consent at any time via the in-game [Privacy Consent Settings — Terms of Service, Privacy Policy] menu, or by emailing ngustudio2020@gmail.com.

6. Security Measures

The Company applies the following reasonable technical and organizational measures to protect personal information:

  • Encryption of data in transit (HTTPS/TLS)
  • Access control with the principle of least privilege
  • Regular security reviews and vulnerability assessments
  • Training of personnel involved in personal information handling

However, no transmission over the Internet can be guaranteed to be 100% secure, and the Company protects personal information within the bounds of reasonable effort.

7. Retention and Deletion Periods

The Company retains personal information for the following periods and destroys it without undue delay once the retention period expires:

  • Account information: retained for the duration of service use; deleted immediately upon account withdrawal
  • Payment and transaction records: 5 years (Act on Consumer Protection in Electronic Commerce)
  • Connection logs: 3 months (Communications Secrets Protection Act)
  • Customer support records: 3 years (Act on Consumer Protection in Electronic Commerce)

Personal information stored in electronic file form is deleted using technical methods that render the records unrecoverable. Information printed on paper is destroyed by shredding or incineration.

8. Your Rights and How to Exercise Them

Under GDPR and the Personal Information Protection Act, you have the following rights:

  • Right of access: obtain confirmation and a copy of your personal information being processed
  • Right to rectification: request correction of inaccurate information
  • Right to erasure ("right to be forgotten"): request deletion of personal information
  • Right to restriction of processing: request that processing be limited in certain circumstances
  • Right to data portability: request transfer of your data to another controller
  • Right to object: object to processing based on legitimate interests or for direct marketing purposes
  • Right not to be subject to automated decision-making: including profiling

You may exercise these rights by contacting ngustudio2020@gmail.com. To prevent impersonation, the Company may request additional information to verify your identity. The Company will respond to your request within 30 days of receipt.

9. Children's Privacy

The Services are not directed to children under 16, and the Company does not knowingly collect personal information from children under 16. If we become aware that personal information of a child under 16 has been collected, we will promptly delete such information and, where possible, notify the parent or guardian.

10. Data Protection Officer (DPO)

The Company has designated the following Data Protection Officer (DPO) to safeguard personal information and handle related complaints:

Data Protection Officer

Name: Park Kyung-Min

Title: CEO

Email: ngustudio2020@gmail.com

11. International Data Transfers and Safeguards

Your personal information is transferred to the Republic of Korea for the operation of the Services. In December 2021, the European Commission adopted an Adequacy Decision recognizing the Republic of Korea as providing an adequate level of protection for personal data of EU residents.

In addition, certain data may be processed through the global infrastructure of our processors (Google, AppLovin, AppsFlyer, etc.). Where this occurs, appropriate safeguards recognized under GDPR — including Standard Contractual Clauses (SCCs) — are applied.

12. Right to Lodge a Complaint with a Supervisory Authority

If you believe that the Company's processing of your personal information infringes your rights, you may lodge a complaint with the supervisory authority in your place of residence or pursue judicial remedies.

  • Republic of Korea: Personal Information Protection Commission (privacy.go.kr) / Personal Information Infringement Reporting Center (118)
  • EU/EEA: the data protection authority (DPA) of your member state. List: edpb.europa.eu

13. Changes to This Privacy Policy

The Company may revise this Privacy Policy from time to time. Where material changes are made, we will provide notice through the in-game announcement or this website at least 7 days before the effective date (30 days where the change is unfavorable to users). The revised policy takes effect on the stated effective date.