Effective Date: October 13, 2025
This Privacy Policy applies to users outside the Republic of Korea and explains how Oneway Ticket Studio Co., Ltd. (“Company,” “we,” “us”) collects, uses, stores, and protects your personal data when you play The Midnight Walkers (the “Game”) and use related services (collectively, the “Services”).
We comply with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), UK GDPR, California Consumer Privacy Act (CCPA), and other relevant privacy laws.
By accessing or using the Game, you acknowledge that you have read and understood this Policy.
We collect the minimum personal data necessary to operate the Game and provide our Services.

• Email address, account name, nickname, and Steam ID/profile name
  
• Country, preferred language, and date of birth
  
• For event participation: name, address, phone number, shipping information, and tax details
  
• For customer inquiries: email address, inquiry details, and any attached files

• IP address, connection logs, time of access, and device information (OS version, hardware specs, language settings)
  
• Game-related data such as play count, game statistics, crash/error reports, and leaderboards
  
• Chat logs and data used for anti-cheat or security purposes
  
• Analytics and website usage data (via cookies or Google Analytics)

• Steam ID and nickname from Valve Corporation (Steam) for account management
  
• Payment and community-related information managed under Steam’s Privacy Policy

We process your data based on the following legal grounds:

• Performance of a contract: to provide and operate the Game and related Services.
  
• Compliance with legal obligations: to meet requirements under applicable laws (tax, consumer protection, export control, etc.).
  
• Legitimate interests: to ensure game security, improve the Game, and maintain fair gameplay.
  
• Consent: where required, we will ask for your explicit consent (e.g., marketing communications). You may withdraw consent at any time.

We use the collected data for the following purposes:

• To operate and provide the Game and related Services
  
• To verify your account and provide customer support
  
• To respond to inquiries and technical issues
  
• To maintain and improve gameplay quality and performance
  
• To conduct events, promotions, and send related rewards
  
• To prevent cheating, fraud, and unauthorized access
  
• To comply with legal requirements and resolve disputes

We retain personal data only as long as necessary for the purposes stated in this Policy or as required by law.

• Data: Email address, nickname
  
• Retention Period: 3 years
  
• Legal Basis: Consumer Protection Act

• Data: Name, address, phone number
  
• Retention Period: Until purpose fulfilled
  
• Legal Basis: —

• Data: User identification data, consent history
  
• Retention Period: 5 years
  
• Legal Basis: E-Commerce Act

• Data: Purchase and transaction information
  
• Retention Period: 5 years
  
• Legal Basis: E-Commerce Act

• Data: Inquiry details, email
  
• Retention Period: 3 years
  
• Legal Basis: E-Commerce Act

• Data: IP address, connection records
  
• Retention Period: 3 months
  
• Legal Basis: Telecommunications Privacy Act

After the retention period ends, data will be securely deleted or anonymized using technical measures (erasure or destruction).
We may transfer your data to trusted service providers located outside your country or region to support the operation of the Game.

• Purpose: Game distribution and account authentication
  
• Location: United States
  
• Retention: Until Service termination

• Purpose: Cloud hosting and data storage
  
• Location: United States / Singapore
  
• Retention: Until Service termination

• Purpose: Anti-cheat detection and security services
  
• Location: China
  
• Retention: Until account deletion or Service termination

We take appropriate safeguards, including Standard Contractual Clauses (SCCs), to ensure that your data is protected in compliance with GDPR and other applicable regulations.
Under applicable laws, you have the following rights regarding your personal data:

• Right of access – You can request copies of your personal data.
  
• Right to rectification – You can request correction of inaccurate or incomplete data.
  
• Right to erasure (“Right to be forgotten”) – You can request deletion of your data under certain conditions.
  
• Right to restrict processing – You can request limitation of how we use your data.
  
• Right to object – You can object to our processing based on legitimate interests.
  
• Right to data portability – You can request that we transfer your data to another organization or to you directly.

If you wish to exercise these rights, please contact us at bmaster@onewayticketstudio.com.
We will respond within bone month, or up to three months for complex requests.
Residents of California may also exercise their rights under the CCPA, including:

• Right to know what personal data we collect
  
• Right to request deletion of personal data
  
• Right to opt out of data sharing for marketing purposes
  
• Right to non-discrimination for exercising privacy rights

Cookies are small text files stored on your device to enhance your browsing and gaming experience.
We use cookies to:

• Keep you signed in
  
• Remember preferences and language
  
• Analyze website usage and improve our Services

You can control or delete cookies in your browser settings. Some features may not function properly if cookies are disabled.
For more information:

• Chrome: Settings → Privacy and Security → Cookies and other site data
  
• Edge: Settings → Cookies and Site Permissions → Manage and delete cookies

We take technical and organizational measures to protect your personal data against unauthorized access, loss, or misuse. These include:

• Access control and encryption
  
• Secure servers and firewalls
  
• Anti-virus and intrusion prevention systems
  
• Regular employee training on data protection

However, no security system is completely foolproof. If a data breach occurs, we will notify affected users and regulators as required by law.
The Game and Services are not intended for users under the age of 13.
We do not knowingly collect personal data from minors without parental consent.
If you believe a child has provided personal data to us, please contact us immediately at master@onewayticketstudio.com.
We have designated a Data Protection Officer (DPO) responsible for ensuring compliance with this Policy:

• Name: Wonhyuk Rhee
  
• Position: Business Director / Data Protection Officer (DPO)
  
• Email: master@onewayticketstudio.com

For questions or complaints, please contact the following authorities as well:

• Korea Internet & Security Agency (KISA): privacy.kisa.or.kr / +82-118
  
• Personal Information Dispute Mediation Committee: kopico.go.kr / +82-1833-6972
  
• Cyber Bureau, Korean National Police Agency: cyber.go.kr / +82-182

We may update this Privacy Policy from time to time.
When we make changes, we will post the updated version on our website and indicate the “Effective Date” above.
If the changes are significant, we will notify you at least 7 days in advance (or 30 days for major changes).
Your continued use of the Game after the effective date means you accept the updated Policy.
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Effective Date: October 13, 2025
Last Updated: October 13, 2025