Summary of new August 2025 Blue Archive EULA - https://store.steampowered.com//eula/3557620_eula_0

1. Summary

This document is a detailed Privacy Policy from Nexon and its affiliated companies (including Embark), explaining how they collect, use, disclose, and protect your personal data when you use their games and services. It covers:

• What types of data are collected (account info, device info, usage data, minors’ data, etc.).
• How your data is used (service provision, marketing, security, analytics, legal compliance).
• Your choices about your data (cookie settings, opting out of emails, withdrawing consent).
• Data subject rights (access, correction, deletion, complaint filing).
• Special rules about minors' data.
• Data security and retention policies.
• International data transfers and legal safeguards.
• Contact details for data protection inquiries.
• An addendum specifically about Embark services, detailing their specific data processing purposes, disclosures, and security.

2. Compliance Analysis

• GDPR: The policy references legal bases for data processing under GDPR (e.g., consent, legitimate interests, contract performance), includes data subject rights, and appoints a representative in the EU.
• CCPA and US State Laws: Includes sections addressing U.S. residents’ rights under state laws.
• Children’s Online Privacy Protection Act (COPPA): Special provisions about minors under 13 and parental rights to access/delete data.
• Cookie and Tracking Transparency: Informs users about cookies, tracking, and opting out mechanisms.
• Data Transfers: Addresses international data transfers, specifying safeguards like Standard Contractual Clauses.
• Opt-out Options: Provides clear instructions on opting out of marketing emails, cookies, and interest-based ads.
• Data Security: Commits to reasonable safeguards but clarifies no system is 100% secure.
• Retention Periods: States retention durations and conditions for data deletion.

Overall, the policy seems robust and aligned with key international privacy laws.

3. Risk Assessment

• Potential Risks to Users:

  • Some data sharing with third-party partners and platforms might expose data to additional risks.
  • Cookies and tracking may affect privacy, although opt-out options are provided.
  • International transfers to countries with potentially lower privacy protections (e.g., US, Korea) might increase risk, mitigated by contractual safeguards.
  • Collection of minors’ data (with parental consent where applicable) entails increased legal responsibility.
  • Deleting or opting out of cookies might limit functionality.
  • “Do Not Track” signals are not honored currently by Nexon.
  • Data retention for up to a year post-relationship could be lengthy for some data types.

• Mitigations:

  • Transparency and clear user rights.
  • Data processing agreements with partners.
  • Ability to contact data protection officers or supervisory authorities.
  • User controls for communications and cookies.
  • Legal bases and GDPR-compliant mechanisms.

4. Simplified Explanation for End Users

What’s collected?
Your username, contact info, device info, IP address, gameplay data, chat, location info, and (if you’re a minor) some personal info with parental consent.

Why collect it?
To provide and improve games/services, help with support, make the game safe from cheats, personalize your experience, and send you relevant updates and offers.

Your choices:

• You can refuse or delete cookies (though some features might break).
• You can opt out of marketing emails anytime.
• You can control what info you share via your device and game settings.
• If you’re a parent, you can review or delete your child’s data.

Your rights:
You can ask to see your info, fix it, move it somewhere else, or delete your account — but some actions might stop you from using the service.

How is your info protected?
They use reasonable security but no system is perfect. Your info may be transferred internationally under strict rules.

Who to contact?
There are email addresses and representatives listed for any questions or concerns.

Would you like me to expand on any of these sections, help draft user-friendly notices, or do anything else?