Personal Information Protection Act Art. 30 · Reflects the April 2025 Revised Guidelines
📌 Notice Survival Shooter : God Spider (the "App") can be used without any sign-up. The App does not operate its own server, and settings such as control layout and language chosen by the user are stored only inside the user's device.
🌍 Notice for Users Outside Korea The App is distributed globally through the App Store and Google Play. In addition to the Republic of Korea's Personal Information Protection Act, this English version of the Policy has been supplemented to reflect the requirements of the EU/UK General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), and the U.S. Children's Online Privacy Protection Act ("COPPA"). Where a right or obligation under these frameworks differs from Korean law, the additional provisions in Articles 13–15 below apply to users in the corresponding region.
01 Purpose of Processing and Items Collected
In accordance with the Personal Information Protection Act, the App collects and uses personal information only to the minimum extent necessary to provide the service.
| Purpose of Processing |
Items Collected |
Legal Basis |
Retention Period |
| Saving control settings (left/right control swap) |
Control-swap setting value (ON/OFF) |
Consent of data subject
(changed directly in the settings screen) |
Until app deletion or settings reset
(stored on device) |
| Maintaining language preference |
Selected language (Korean/English) |
Consent of data subject
(language toggle button click) |
Until the app is relaunched
(temporarily stored on device, never sent to a server) |
| Providing the revive feature after watching a rewarded ad |
Advertising identifier (ADID) and other device information
(processed via the Google AdMob SDK) |
Consent of data subject
(tapping the "watch ad" button) |
Governed by Google AdMob's policy
(the App itself does not separately store this) |
Note on declining consent: Control-swap and language settings are for user convenience — leaving them unset simply keeps the defaults (swap OFF, the language of your device/browser) and does not affect gameplay. Watching a rewarded ad (revive feature) is optional; declining to watch it does not affect normal gameplay (shooting, wave progression, etc.).
02 Retention and Use Period
Because the App has no sign-up/login process and runs no server of its own, any settings changed by the user are, in principle, stored only inside the user's device (local/session storage) and are immediately deleted when the app is deleted or the device storage is reset.
Control-swap setting
Stored in the device's local storage (localStorage) and never transmitted to a server. It persists until the user changes it again or deletes the app.
Language setting
Temporarily stored in the device's session storage (sessionStorage) and is automatically cleared once the app (browser tab) is fully closed.
Ad identifier and other device information
Processed by the Google AdMob SDK for the purpose of serving rewarded ads; the App itself does not collect or store this information. The retention period follows Google's own policy.
Gameplay information such as score and wave
Never transmitted to a server or permanently stored; it disappears once the game ends or restarts. See Article 5 for details.
03 Provision of Personal Information to Third Parties
The App does not, in principle, provide personal information to third parties. The following are exceptions:
- Where the data subject has given separate consent
- Where required by specific provisions of law or unavoidable to comply with a legal obligation
- Where the data subject or their legal representative is unable to express intent, or their address is unknown, making prior consent impossible, and it is clearly necessary for the life, body, or property interests of the data subject or a third party
The App currently does not provide user information to any third party under separate contract. However, to provide rewarded ads, the Google AdMob SDK independently processes device information such as advertising identifiers, and this is handled anonymously without identifying any member. (See Article 4.)
04 External Service (Ad SDK) Integration
Without operating its own server, the App calls the following external service (an advertising SDK) directly from the user's device to provide certain features. While this differs from a traditional outsourcing arrangement, it is disclosed here for transparency.
| Recipient |
Data Transmitted/Processed |
Purpose of Use |
Remarks |
| Google AdMob (Google LLC) |
Advertising identifier (ADID) and other device information |
Serving rewarded ads and providing an in-game revive upon completed viewing |
Google's separate privacy policy applies |
For details on Google AdMob, please refer to Google's Privacy Policy (policies.google.com/privacy).
Cross-border transfer: Google AdMob is operated by Google LLC in the United States, so device information processed through the SDK may be transferred to and processed in the United States and other countries where Google operates. Google participates in the EU–U.S. Data Privacy Framework and relies on the European Commission's Standard Contractual Clauses (SCCs) and comparable safeguards to protect data transferred from the EEA, the UK, and Switzerland. You may contact us using the details in Article 10 for more information about these safeguards.
05 Processing of Gameplay Information
The App is a shooting game in which the player pilots a ship (God Spider) to defeat enemies and progress through waves. Gameplay information generated in this process — such as score, kill count, wave stage, and health — is non-identifying game data and is processed as follows.
How it's processed
Score, wave, kill count, and similar values are calculated and displayed only in volatile memory while the app is running, and are never sent to any storage or server.
Retention and deletion
When the game is restarted or the app is closed, that session's progress information is immediately erased and cannot be recovered.
Note: If a future update adds server-connected features such as a leaderboard, this Privacy Policy will be revised in advance to separately disclose the new items collected and their purposes.
06 Rights and Obligations of Data Subjects
Data subjects may exercise the following rights with respect to the App at any time.
| Type of Right |
Description |
Relevant Provision |
| Right to request access |
You may check the personal information (control/language settings, etc.) the App processes about you. (Directly viewable in the in-app "Settings" screen.) |
PIPA Art. 35 |
| Right to request correction/deletion |
If setting information being processed (control swap, language, etc.) is inaccurate or unnecessary, you may correct, delete, or reset it directly within the App. |
PIPA Art. 36 |
| Right to request suspension of processing |
You may request that processing of your setting information be temporarily suspended. |
PIPA Art. 37 |
| Right to withdraw consent |
You may withdraw your consent to the storage of setting values and to ad viewing at any time (by resetting settings or not using the ad-viewing feature). |
PIPA Art. 37 |
In accordance with Article 41(1) of the Enforcement Decree of the Personal Information Protection Act, rights may be exercised via email, and we will take action within 10 days of receiving the request.
- For children under the age of 14, a legal representative may exercise these rights.
- When exercising rights through an agent, a power of attorney in the form specified in Annex 11 of the "Notice on Methods of Processing Personal Information" (Notice No. 2025-4) must be submitted.
- Requests for access and suspension of processing may be restricted under Articles 35(4) and 37(2) of the Personal Information Protection Act.
07 Destruction of Personal Information
When the purpose of retention has been achieved or the user requests deletion/reset, the App destroys the relevant personal information without delay.
| Destruction Procedure | Destruction Method |
|---|
When device storage is reset
All control-swap and language settings, etc. are deleted |
Permanent deletion of data in device storage (localStorage/sessionStorage); unrecoverable |
When the app is deleted
All remaining setting data on the device is deleted together |
Follows the operating system's app-data deletion procedure |
08 Measures to Ensure Security
In accordance with Article 29 of the Personal Information Protection Act, the App takes the following measures to ensure security.
- Data minimization: No sign-up/login process is used, and setting information is designed to be processed only on the device, in principle blocking transmission to any server
- Administrative measures: Disclosure of processing status through this Privacy Policy, and minimization of handling
- Technical measures: Gameplay information (score, wave, etc.) is processed only in memory and never stored on a separate server
- Guaranteeing user control: An in-app settings-reset feature is provided so users can directly manage their own setting information
09 Automatic Collection Devices and Advertising Identifiers
The App does not use any separate in-house analytics tool. However, to provide rewarded ads, the following information may be processed via the advertising SDK.
| Collecting Party | Items Collected | Purpose of Use | How to Opt Out |
|---|
| Google AdMob |
Advertising identifier (ADID), device/OS information |
Serving rewarded ads and providing an in-game revive upon completed viewing |
Device Settings → disable ad personalization, or simply don't use the ad-viewing (revive) feature in the App |
Personalized ads: Ad serving is performed independently by the Google AdMob SDK; the App itself does not separately collect or analyze user behavioral data.
iOS App Tracking Transparency: On devices running iOS 14.5 or later, the App displays Apple's App Tracking Transparency ("ATT") prompt before any identifier is used for cross-app tracking. If you choose "Ask App Not to Track," the App and AdMob will not use the Identifier for Advertisers (IDFA) for personalized advertising, and only non-personalized, contextual ads (or no rewarded ads) will be served.
Android: You may limit ad personalization or reset your advertising ID at any time via Settings → Google → Ads on your Android device.
10 Data Protection Officer
The App designates the following Data Protection Officer, who is responsible for overseeing personal information processing and handling complaints and remedies for data subjects. For purposes of the GDPR and CCPA, this same individual acts as the data controller/business responsible for the App.
11 Remedies for Infringement of Rights
Data subjects may apply to the following institutions for dispute resolution or consultation to seek remedies for damages caused by infringement of personal information.
| Institution | Contact | Website |
|---|
Personal Information Protection Commission
Privacy Infringement Report Center |
182 (no area code) |
privacy.go.kr |
| Personal Information Dispute Mediation Committee |
1833-6972 (no area code) |
www.kopico.go.kr |
| Supreme Prosecutors' Office Cyber Crime Investigation Division |
1301 (no area code) |
www.spo.go.kr |
| National Police Agency Cyber Bureau |
182 (no area code) |
cyberbureau.police.go.kr |
12 Changes to this Policy
This Privacy Policy is effective as of August 12, 2026.
The content may be added to, removed, or modified in accordance with laws and internal policy; any changes will be announced in advance through in-app notices. Significant changes will be announced 7 days before taking effect, and changes materially affecting data subjects' rights (items collected, purpose of use, etc.) will be announced 30 days in advance.
| Version | Effective Date | Key Changes |
|---|
| v1.0 |
Aug 12, 2026 |
Initial enactment — reflects the Personal Information Protection Commission's April 2025 revised guidelines (Notice No. 2025-4). Discloses storage of control/language settings and integration of the rewarded-ad SDK (Google AdMob, revive feature), and reflects the principle that gameplay information (score, wave, etc.) is processed non-persistently. |
13 Additional Rights for EEA/UK Users (GDPR)
If you are located in the European Economic Area, the United Kingdom, or Switzerland, the following supplementary provisions apply to you under the General Data Protection Regulation and the UK GDPR.
| Processing Activity | Legal Basis (GDPR Art. 6) |
|---|
| Storing control-swap and language settings |
Consent (Art. 6(1)(a)) — you may withdraw consent at any time by resetting the setting |
| Serving rewarded ads via Google AdMob |
Consent (Art. 6(1)(a)), collected through the ad SDK's consent mechanism before any non-essential identifier is used |
| Core gameplay functions (score, wave, health, processed in-memory only) |
Performance of the app's core function / legitimate interest (Art. 6(1)(f)); no personal data leaves your device |
In addition to the rights listed in Article 6, EEA/UK/Swiss users have the following rights under the GDPR:
- Right to data portability — request that setting data we hold be provided to you in a structured, commonly used, machine-readable format
- Right to object — object to processing based on legitimate interest, including ad-related processing carried out by the AdMob SDK
- Right to lodge a complaint — you may lodge a complaint with the data protection supervisory authority of your habitual residence, place of work, or the place of the alleged infringement (for example, the Irish Data Protection Commission for users in Ireland, or your national Data Protection Authority)
No automated decision-making: The App does not carry out any automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you.
14 Additional Rights for California Residents (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, grants you the additional rights described below with respect to the personal information collected by the App.
| Category of Personal Information | Collected? | Sold or Shared? |
|---|
| Identifiers (advertising identifier / ADID) |
Yes, only when the rewarded-ad feature is used |
Not sold for money. May be considered "shared" for cross-context behavioral advertising through the Google AdMob SDK |
| Internet or other electronic network activity (in-app ad interaction) |
Yes, only via the AdMob SDK |
Same as above |
| Precise geolocation, biometric data, financial information, etc. |
No |
Not applicable |
California residents may exercise the following rights by contacting us at the email address in Article 10:
- Right to know — request the categories and specific pieces of personal information collected about you in the preceding 12 months
- Right to delete — request deletion of personal information we have collected from you, subject to certain exceptions
- Right to correct — request correction of inaccurate personal information
- Right to opt out of sale/sharing — opt out of any "sale" or "sharing" of personal information for cross-context behavioral advertising, by disabling ad personalization in your device settings or by not using the rewarded-ad (revive) feature
- Right to non-discrimination — we will not deny goods or services, charge different prices, or provide a different level of service because you exercised a CCPA right
Verification: Because the App does not require sign-up and does not maintain user accounts, we may only be able to verify and respond to requests to the extent identifying information is available (e.g., a device-specific setting). We do not sell personal information for monetary consideration and have not done so in the preceding 12 months. We have not used or disclosed sensitive personal information for purposes requiring an opt-out right under the CPRA.
15 Children's Privacy (COPPA) and Age Requirements
The App is intended for a general audience and is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13 without verifiable parental consent, in accordance with the U.S. Children's Online Privacy Protection Act ("COPPA").
- Core gameplay does not require the input of any personal information, and no sign-up is necessary to play.
- The rewarded-ad feature (Google AdMob) is configured to serve only non-personalized, contextual ads whenever the App determines, or a parent/guardian indicates, that the player may be a child, consistent with Google's Families policies.
- If we become aware that we have inadvertently collected personal information from a child under 13 without the required parental consent, we will delete such information promptly.
- For users in the EEA/UK, the age at which a child can independently consent to data processing under GDPR Article 8 ranges from 13 to 16 depending on the member state; where the applicable age has not been reached, consent of a parent or legal guardian is required before using features that involve any processing of personal information.
Parents or legal guardians who believe their child has provided personal information to the App may contact us at the email address listed in Article 10 to review, request deletion of, or refuse further collection of such information.