Privacy Policy

Last updated: June 26, 2026

This Privacy Policy describes how Atomrigs Lab, Inc. collects, uses, discloses, and protects information when You use OpenRPG.ai: Divergence.

By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

Words with the initial letter capitalized have meanings defined under the following conditions. The following definitions have the same meaning regardless of whether they appear in singular or plural.

Definitions

• Application means the software program provided by the Company, named OpenRPG.ai: Divergence.
• Company, also referred to as “We”, “Us”, or “Our”, means Atomrigs Lab, Inc., 4F 415, Bongeunsa-ro, Gangnam-gu, Seoul, Republic of Korea.
• Service means the Application, Website, game services, AI-powered features, and related services provided by the Company.
• Website means OpenRPG.ai: Divergence, accessible from https://divergence.openrpg.ai/.
• Account means a unique account created for You to access the Service or parts of the Service.
• Personal Data means information that identifies, relates to, describes, or can reasonably be linked to an identified or identifiable individual.
• Usage Data means data collected automatically when using the Service.
• Service Provider means a third-party company or individual that processes data on behalf of the Company.
• Minimum Age means the minimum age required to use the Service without parental or guardian consent, which is 14 years of age in the Republic of Korea and the minimum age required under applicable law in other jurisdictions (for example, 13 years under the U.S. Children’s Online Privacy Protection Act, and the applicable age of digital consent, generally 16 years and not lower than 13 years, in the European Economic Area).
• You means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service.

Information We Collect

Personal Data You Provide

While using the Service, We may ask You to provide certain information that can be used to contact or identify You, including:

• Email address
• Display name, account name, or profile information
• Login authentication information provided through supported login providers. If You sign in through a third-party login or social media provider, We may receive basic profile information (such as Your name and email address) associated with that account, in accordance with that provider’s settings and policies.
• Customer support communications
• Information submitted through forms, surveys, event registrations, feedback forms, or promotional programs

Game and Service Data

We may collect and process information generated through Your use of the Service, including:

• Player ID and account identifiers
• Game progress, character information, gameplay records, achievements, rankings, event participation records, and reward history
• Virtual items, in-game resources, missions, battle records, and other game activity
• Preferences, settings, and interaction history within the Service

AI Service Data

The Service may include AI-powered features, such as AI-driven conversations and chat with characters provided in the Service. When You use these features, We may process the messages You send, Your selections and settings, generated outputs, interaction history, and related metadata for the purpose of generating responses, operating the Service, improving functionality, debugging, preventing abuse, ensuring safety, and protecting system security.

You should not submit sensitive personal information or confidential information through AI-powered features unless it is necessary for Your use of the Service.

We use commercially reasonable measures, including automated filtering and moderation, to reduce the risk that AI-powered features generate harmful, unlawful, or age-inappropriate content. However, because AI-Generated Content is produced automatically, We cannot guarantee that all such content will be prevented. You can report inappropriate content using the contact information below.

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your IP address, browser type, browser version, device type, operating system, pages or features used, time and date of access, time spent in the Service, unique device identifiers, crash logs, diagnostic data, and other technical information.

Cookies and Similar Technologies

We may use cookies, local storage, pixels, tags, scripts, and similar technologies to operate and improve the Service, authenticate users, remember preferences, analyze usage, prevent fraud, and improve performance.

You can instruct Your browser to refuse cookies or to indicate when a cookie is being sent. However, some parts of the Service may not function properly without cookies or similar technologies.

Blockchain Wallet Information

The Service does not currently provide blockchain wallet connection functionality as part of normal Service operation. We do not currently collect or process blockchain wallet addresses through a wallet connection feature. If wallet-related features are introduced in the future, this Privacy Policy will be updated as appropriate.

How We Use Personal Data

We may use Personal Data for the following purposes:

• To provide, operate, maintain, and improve the Service.
• To create, authenticate, manage, and secure Accounts.
• To store and manage game progress, rankings, rewards, achievements, events, and other gameplay features.
• To provide AI-powered features and generate AI-related outputs.
• To detect, prevent, and respond to fraud, cheating, abuse, security incidents, technical issues, or violations of Our Terms.
• To provide customer support and respond to inquiries or requests.
• To send service-related notices, updates, security alerts, administrative messages, and important information about the Service.
• To send marketing, promotional, or event-related communications where permitted by law and subject to Your choices.
• To analyze usage trends, measure performance, test features, and improve user experience.
• To comply with legal obligations, enforce agreements, and protect the rights, property, and safety of the Company, users, and others.

How We Share Personal Data

We may share Personal Data in the following situations:

• With Service Providers: We may share Personal Data with vendors that help Us operate, host, analyze, secure, support, email, or improve the Service.
• With payment processors or app platforms: If paid features are provided, payments may be processed by third-party platforms or payment processors under their own terms and privacy policies.
• For events and promotions: We may process or disclose limited information as necessary to verify eligibility, distribute rewards, prevent fraud, or administer events.
• With other users: Certain information, such as display name, profile, rankings, achievements, or public activity, may be visible to other users within the Service.
• For business transfers: Personal Data may be transferred in connection with a merger, acquisition, financing, restructuring, sale of assets, or similar business transaction.
• For legal and safety reasons: We may disclose Personal Data if required by law or if We believe disclosure is necessary to protect rights, safety, security, prevent abuse, or respond to lawful requests.
• With Your consent: We may disclose Personal Data for other purposes with Your consent.

Service Providers

We may use third-party Service Providers to support the Service. These providers may process Personal Data on Our behalf in accordance with their own privacy policies and Our instructions where applicable.

The providers listed below reflect the third parties currently used in the Service. We will keep this list updated and will not list providers that are not actually used in the Service.

Analytics

We may use analytics providers such as Google Analytics to understand how users interact with the Service and improve performance. We list only analytics providers that are actually used in the Service.

You can learn more about, and where available opt out of, these analytics services through the following resources: Google Analytics — privacy policy and the Google Analytics opt-out browser add-on.

Email Communications

We may use email service providers such as Resend (privacy policy) to send service-related, transactional, marketing, or event-related emails. You may opt out of marketing emails by following unsubscribe instructions where provided or by contacting Us.

Payments

If paid products or services are provided, payments may be processed by third-party platforms or processors, such as Apple App Store, Google Play, Xsolla, or other providers. We do not store full payment card details where payments are processed directly by third-party payment processors. These processors handle payment information under their own privacy policies and adhere to applicable payment-security standards such as PCI-DSS. You can review their privacy policies here: Apple, Google, Xsolla.

Customer Support

We may use customer support tools such as Zendesk (privacy policy) to manage inquiries and user communications.

Error Monitoring and Diagnostics

We may use error-monitoring and diagnostics providers such as Sentry, operated by Functional Software, Inc. (privacy policy), to detect, analyze, and resolve errors and improve the stability of the Service. When an error occurs, technical information such as IP address, device information (operating system, device model, app version), browser information, error logs, stack traces, environment information, and event timestamps may be transmitted to this provider over encrypted (HTTPS/TLS) connections.

Retention of Personal Data

We retain Personal Data only for as long as necessary for the purposes described in this Privacy Policy, including to provide the Service, maintain Account and game data, comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, maintain security, and support legitimate business operations.

The general retention periods or criteria We apply are set out below. Where applicable law requires a specific retention period (for example, under the Republic of Korea’s Act on the Consumer Protection in Electronic Commerce or the Protection of Communications Secrets Act), the period required by law applies.

Certain records may be retained after Account deletion where retention is permitted or required by law, or where necessary for fraud prevention, security, dispute resolution, accounting, legal compliance, or enforcement of Our Terms.

Usage Data is generally retained for a shorter period unless it is needed to improve security, prevent abuse, maintain functionality, or comply with legal obligations.

Transfer of Personal Data

Your information may be processed at the Company’s operating offices and in other locations where the Company or its Service Providers operate. These locations may be outside Your country or region and may have data protection laws that differ from those in Your jurisdiction.

Where required by applicable law, We will take reasonable steps to ensure appropriate safeguards for the transfer and processing of Personal Data.

Where We transfer Personal Data overseas and applicable law (including the Republic of Korea’s Personal Information Protection Act) requires it, We will inform You of, or make available, the following: the items of Personal Data transferred; the country to which the data is transferred; the date, time, and method of transfer; the name of the recipient and its contact information; and the purposes and retention period of the recipient’s use. Where required, We rely on appropriate safeguards such as standard contractual clauses or equivalent mechanisms.

Security of Personal Data

We use commercially reasonable measures to protect Personal Data. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, We cannot guarantee absolute security.

Your Choices and Rights

Depending on Your location and applicable law, You may have rights to access, correct, delete, restrict, object to, or request a copy of certain Personal Data. You may also have the right to withdraw consent where processing is based on consent.

You may contact Us to request access to, correction of, or deletion of Personal Data that You have provided to Us. We may ask You to verify Your identity before responding to a request.

Please note that We may need to retain certain information where We have a legal obligation or legitimate basis to do so.

To exercise any of these rights, You may contact Us using the details in the “Contact Us” section. We may ask You to verify Your identity before responding, and an authorized agent may submit a request on Your behalf with proof of authorization. We will respond within the timeframe required by applicable law (for example, within 30 days under the Republic of Korea’s Personal Information Protection Act, and within 45 days under the California Consumer Privacy Act, each extendable where the law permits). We do not charge a fee for handling Your request unless permitted by law, and We will not discriminate against You for exercising Your rights.

Marketing Communications

We may use Your email address to send newsletters, promotional materials, event notices, or other information that may be of interest to You, where permitted by applicable law. You may opt out of receiving marketing communications by following unsubscribe instructions in the email or by contacting Us.

Where required by applicable law, including for users in the Republic of Korea under the Act on Promotion of Information and Communications Network Utilization and Information Protection, We will obtain Your prior consent before sending advertising or promotional communications, will clearly identify such communications as advertising, and will observe restrictions on sending advertising communications during night-time hours. You may withdraw Your consent at any time.

Even if You opt out of marketing communications, We may still send non-promotional messages such as service notices, security alerts, Account information, or transactional messages.

Children’s Privacy

The Service is intended for users who meet the applicable Minimum Age. We do not knowingly allow children below the applicable Minimum Age to create an Account or use the Service without the consent or supervision of a parent or legal guardian where required by applicable law. In the Republic of Korea, children under 14 years of age may use the Service only with the consent of a legal guardian, and We will take steps to verify such consent where required.

We do not knowingly collect Personal Data from children below the applicable Minimum Age without required parental or guardian consent. If We become aware that We have collected Personal Data from such a child without required consent, We will take reasonable steps to delete that information without undue delay.

If You are a parent or legal guardian and believe that a child has provided Us with Personal Data without required consent, please contact Us so that We can review and, where appropriate, delete the information.

GDPR Privacy Notice

If You are located in the European Economic Area, United Kingdom, or another jurisdiction with similar laws, We may process Personal Data under one or more legal bases, including consent, performance of a contract, compliance with legal obligations, legitimate interests, or protection of vital interests.

More specifically, We rely on the following legal bases under the GDPR: (i) Consent, where You have given consent for one or more specific purposes; (ii) Performance of a contract, where processing is necessary to provide the Service or take steps at Your request before entering into a contract; (iii) Legal obligations, where processing is necessary to comply with the law; (iv) Vital interests, where processing is necessary to protect Your or another person’s vital interests; and (v) Legitimate interests, where processing is necessary for Our legitimate interests (such as securing the Service, preventing fraud and abuse, and improving the Service), provided these are not overridden by Your rights and interests. Where We rely on legitimate interests, You may request further information about the balancing We have carried out.

You may have rights to access, rectify, erase, restrict, object to processing, request data portability, or withdraw consent. You may also have the right to lodge a complaint with a data protection authority.

Where Our processing is based on consent, You may withdraw that consent at any time without affecting the lawfulness of processing before withdrawal. You also have the right to object to processing based on legitimate interests and to object at any time to processing of Your Personal Data for direct marketing purposes. If You are in the EEA or the UK, You may lodge a complaint with Your local supervisory authority. We act as the Data Controller for Personal Data processed in connection with the Service, and We will identify an EU/UK representative where one is required by applicable law.

California Privacy Notice

If You are a California resident, You may have rights under California privacy laws, including the right to know, access, correct, delete, opt out of certain sharing or sales, limit certain uses of sensitive personal information, and not be discriminated against for exercising Your rights.

We do not sell Your personal information, and We do not share it for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA. The Service does not run targeted or interest-based advertising. We use a limited number of analytics providers to operate and improve the Service, and We do not use Your personal information to serve You personalized ads.

To exercise applicable privacy rights, please contact Us using the contact information below. We will verify Your request and respond within the timeframe required by law, and We will not discriminate against You for exercising Your rights.

Sensitive Personal Information

To the extent We process any sensitive personal information, We use and disclose it only as necessary to provide the Service and for other purposes permitted by law that do not require an option to limit.

Minors

California residents under 18 who are registered users may request removal of content or information they have publicly posted on the Service by contacting Us with the email address associated with their account. Removal may not be complete or comprehensive where the law does not require it or where the content was reposted by others.

Do Not Track

Some browsers may transmit “Do Not Track” signals. Because there is no uniform standard for how to respond to such signals, the Service does not currently respond to Do Not Track signals.

Links to Other Websites

The Service may contain links to third-party websites or services that are not operated by Us. We are not responsible for the content, privacy policies, or practices of third-party websites or services. We encourage You to review the privacy policy of every third-party service You visit.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify You of changes by posting the new Privacy Policy on this page and updating the “Last updated” date. Where required by law, We may provide additional notice.

Contact Us

If You have any questions about this Privacy Policy or wish to exercise privacy rights, You can contact Us by email: [email protected]

Personal Information Protection Officer (for inquiries from users in the Republic of Korea): Atomrigs Lab, Inc., 4F 415, Bongeunsa-ro, Gangnam-gu, Seoul, Republic of Korea, email [email protected]. You may also lodge a complaint with the Personal Information Protection Commission or the Korea Internet & Security Agency (KISA) Privacy Center where applicable.