Terms Watch

END USER SOFTWARE LICENSE AGREEMENT
PLEASE BE ADVISED THAT SECTION 20 CONTAINS BINDING ARBITRATION AND A WAIVER OF CLASS ACTION THAT MAY AFFECT YOUR RIGHTS FOR RESOLVING ANY DISPUTE WITH THE COMPANY.

1. GENERAL 
1.1 PLEASE READ THIS END USER LICENSE AGREEMENT ("AGREEMENT") CAREFULLY BEFORE INSTALLING OR USING "THE MIDNIGHT WALKERS" (THE "GAME"). BY INSTALLING, COPYING, OR OTHERWISE USING THE GAME, YOU AGREE TO BE BOUND BY THE TERMS OF THIS AGREEMENT AS SET FORTH BY ONEWAY TICKET STUDIO ("COMPANY").
1.2 This Agreement is a legal agreement between you and Company and its affiliates, suppliers, and licensors (collectively, "Provider") regarding your use of the Game and any updates or patches thereto.
1.3 By installing or using the Game, you also agree to comply with the terms of any applicable Third‑Party Marketplace (as defined below), including but not limited to Steam®, Xbox™, PlayStation™, the Epic Games Store, and any other platform where the Game is distributed (each, a "Third‑Party Marketplace").
1.4 If you do not agree to all terms of this Agreement, do not install or use the Game.
1.5 Company may modify this Agreement at any time in its sole discretion. Continued use of the Game after such modifications constitutes acceptance of the revised Agreement.

2. LICENSE GRANT AND RESTRICTIONS 
2.1 Subject to your compliance with this Agreement, Company hereby grants you a non-exclusive, non-assignable, non-transferable, revocable, limited license to download, install, and use the Game and related documentation (the "Documentation") solely for personal, non-commercial purposes, in accordance with this Agreement and subject to payment of applicable license fees. You are prohibited from leasing, renting, distributing, selling, sublicensing, or otherwise transferring the Game or any rights therein, whether for commercial or non-commercial purposes. You may not install the Game on a network server, use the Game in a time-sharing arrangement, or otherwise use the Game in any unauthorized manner. No license is granted to you for access to the Game's human-readable source code or for reverse engineering, decompiling, disassembling, or otherwise attempting to derive the source code or underlying ideas or algorithms of the Game, except to the extent explicitly permitted by applicable law notwithstanding this limitation. This license does not convey any ownership rights or rights to patents, copyrights, trade secrets, trademarks, or any other intellectual property associated with the Game and Documentation. Company retains sole ownership of all rights, title, and interest in the Game and Documentation.
2.2 You agree NOT to: (i) copy, distribute, publicly display, sublicense, sell, rent, lease, or otherwise exploit the Game except as expressly permitted; (ii) modify, reverse engineer, decompile, or disassemble the Game except to the extent such activity is expressly permitted by applicable law notwithstanding this restriction; (iii) remove or alter any proprietary notices or labels within the Game; (iv) use any unauthorized software, bots, hacks, or exploits to modify or interfere with the Game; (v) upload the Game or any part thereof to a server for public or commercial use without Company’s prior written consent.
2.3 Virtual Currency & Virtual Goods (a) The Game may include virtual currency ("Virtual Currency") and/or virtual items ("Virtual Goods"). Virtual Currency and Virtual Goods are licensed, not sold, and may only be used within the Game. (b) All purchases of Virtual Currency and Virtual Goods are final and non‑refundable except as required by law or at Company’s sole discretion. (c) Company may add, modify, suspend, or eliminate Virtual Currency or Virtual Goods at any time without liability.

3. INTELLECTUAL PROPERTY 
3.1 All intellectual property rights in and to the Game, including but not limited to trademarks, service marks, logos, graphics, designs, text, images, software, and audiovisual content, are owned by Company or its licensors. Except for the limited license granted herein, no rights are transferred to you.
3.2 "The Midnight Walkers", "Oneway Ticket Studio", and related marks are trademarks or registered trademarks of Company. You may not use Company’s marks without prior written permission.

4. USER-GENERATED CONTENT
4.1 Ownership of User Generated Content. You retain ownership of any content you create, upload, or otherwise submit through or in connection with the Game ("User-Generated Content").
4.2 License to Company. By creating, uploading, or submitting User-Generated Content, you grant Company and its affiliates a non-exclusive, perpetual, worldwide, royalty-free, sublicensable, irrevocable license to use, reproduce, distribute, modify, adapt, publicly display, publicly perform, create derivative works from, and otherwise exploit your User-Generated Content for any purpose related to the operation, development, promotion, and marketing of the Game or related services. This license extends to all formats, media, or distribution methods now known or later developed, and includes the right to use your UGC in connection with promotional materials, social media campaigns, and community forums.
4.3 Compliance with Rules and Laws. You represent and warrant that your User-Generated Content:
(a) is your original creation or that you have obtained all necessary rights, licenses, and permissions to submit it;
(b) does not infringe on any intellectual property rights, privacy rights, or other rights of any third party;
(c) does not violate any applicable laws, rules, or regulations; and
(d) complies with any guidelines, rules, or policies set forth by Company or the Steam platform.
4.4 Right to Monitor and Remove. Company reserves the right, but has no obligation, to monitor, review, or remove any User-Generated Content at its sole discretion for any reason, including if the content is deemed to be inappropriate, harmful, unlawful, infringing, or otherwise in violation of this Agreement or Company’s policies. Company is not responsible for any loss or harm resulting from the removal or modification of User-Generated Content.
4.5 No Expectation of Compensation or Confidentiality. You agree that you are not entitled to any compensation, credit, or attribution for Company’s use of your User-Generated Content, unless expressly agreed upon in writing by Company. You further acknowledge that Company is under no obligation to treat your User-Generated Content as confidential.
4.6 Indemnification. You agree to indemnify, defend, and hold harmless Company, its affiliates, suppliers, and resellers from and against any and all claims, losses, liabilities, damages, expenses, and costs (including reasonable attorneys’ fees) arising out of or related to your User-Generated Content, including claims that it infringes any third-party rights or violates any laws or regulations.

5. FEEDBACK
5.1 Ownership of Feedback. You agree that any feedback, suggestions, ideas, enhancements, recommendations, or other information you provide to Company, whether orally, in writing, or electronically, in connection with the Game, its performance, or any related services (collectively, "Feedback"), shall become the sole and exclusive property of Company.
5.2 License Grant to Company. To the extent that you retain any rights in the Feedback, you hereby grant Company and its affiliates a perpetual, worldwide, royalty-free, irrevocable, sublicensable, and transferable license to use, reproduce, distribute, publicly display, publicly perform, modify, adapt, create derivative works from, and otherwise exploit the Feedback for any purpose, including but not limited to improving the Game, developing new products or services, and marketing or promotional activities, without obligation, restriction, or compensation to you.
5.3 No Confidentiality. You acknowledge and agree that Company is under no obligation to treat Feedback as confidential, unless otherwise expressly agreed in writing. Company shall not be liable for any disclosure or use of the Feedback.
5.4 Waiver of Moral Rights. To the extent permitted by applicable law, you waive any moral rights or other rights in the Feedback that may require attribution of authorship or limit Company’s ability to modify, adapt, or use the Feedback in any way.
5.5 Acknowledgment of Development Activities. You acknowledge that Company may already be independently developing ideas, features, or products similar to the Feedback or that your Feedback may overlap with existing projects. Providing Feedback does not create any obligation for Company to use, implement, or acknowledge your contribution.
5.6 No Obligation to Use. Company is under no obligation to use, implement, or respond to any Feedback you provide.

6. NO ASSIGNMENT; NO TRANSFER. You agree that this Agreement and the license granted to you for the Game and Documentation are personal to you and may not be assigned, transferred, sublicensed, or otherwise conveyed to any other party without the prior written consent of Company. Any attempted assignment or transfer in violation of this provision shall be null and void. If Company provides prior written consent for the transfer or assignment of the Game and/or this Agreement, you must: (a) transfer all copies of the Game and Documentation to the same party; or (b) permanently delete or destroy any remaining copies of the Game and Documentation that are not transferred. Notwithstanding the foregoing, you acknowledge that this Agreement does not grant you ownership rights to the Game, and any transfer of the Game remains subject to Company's ongoing rights and this Agreement. For clarity, you may not: (x) sell, rent, lease, sublicense, distribute, or otherwise transfer the Game, including but not limited to any digital account or access credentials associated with the Game; or (y) share access to the Game with any other party, whether for commercial or non-commercial purposes.

7. STEAM TERMS OF SERVICE. The Game is distributed through the Steam platform, which is operated by Valve Corporation (“Steam”). You acknowledge and agree that your use of the Game is also subject to Steam’s Terms of Service, Privacy Policy, and any other applicable agreements or policies maintained by Steam (collectively, the “Steam Terms”). Both you and Company are required to comply with the Steam Terms. In the event of a conflict between this Agreement and the Steam Terms, the Steam Terms shall govern to the extent required by Steam’s policies. Company is not responsible for any actions taken by Steam, including but not limited to account restrictions, bans, or enforcement of Steam’s Terms of Service, which may affect your access to the Game. You further acknowledge that refunds, payment processing, and other platform-related policies are governed by Steam and are not under the control of Company. Any disputes or claims arising from your use of Steam or its services must be resolved in accordance with the Steam Terms. By using the Game on Steam, you agree to abide by both this Agreement and the Steam Terms. Company reserves the right to update this Agreement as necessary to remain compliant with the Steam Terms or any changes thereto.

8. USER CONDUCT 
8.1 You agree to use the Game only for lawful purposes and in a manner that does not infringe the rights of or restrict the enjoyment of the Game by any third party.
8.2 Violation of this Agreement or any additional rules of conduct published by Company may result in suspension or termination of your access to the Game.
8.3 External Misconduct. Company reserves the right, in its sole discretion, to deny, suspend, or terminate access to the Game or related services if a user: (a) engages in conduct outside the Game that is unlawful, promotes violence or hate, or otherwise brings material disrepute or harm to the Game, the community, or Company; or (b) is reasonably believed to pose a risk to the safety, well‑being, or orderly enjoyment of other users. Company’s decision under this clause is final and may be made without prior notice.

9. TECHNICAL REQUIREMENTS. You are responsible for ensuring that your hardware, software, and internet connection meet the minimum requirements to run the Game.

10. UPDATES AND PATCHES.  Company may deploy patches, updates, or other modifications ("Updates") to the Game that must be installed for continued use. You consent to such Updates being automatically installed without additional notice.

11. DATA COLLECTION & PRIVACY.  Company may collect and process data as described in the Company Privacy Policy, including technical information about your device and gameplay statistics. By using the Game, you consent to such data collection and processing.

12. EPILEPSY WARNING.  A small percentage of people may experience epileptic seizures or other issues when exposed to flashing lights or certain visual images. Consult your physician prior to playing if you have any concerns and discontinue use immediately if you experience any adverse symptoms.

13. ACCOUNT SUSPENSION & TERMINATION 
13.1 Company may suspend or terminate your account or access to the Game at any time for conduct that Company deems violates this Agreement or the spirit of the Game.
13.2 You may discontinue use of the Game at any time by uninstalling it. No refunds will be provided for Virtual Currency, Virtual Goods, or unused services except as required by law.
13.3 By agreeing to these terms, you acknowledge that Company has sole discretion to enforce these measures and that such actions are necessary to maintain the integrity, security, and enjoyment of the Game for all users.
13.4 Community Integrity
Notwithstanding any other provision, Company may stop providing any service to individuals or entities whoes behavior is likely to create, encourage, or cause any controversy that disrupts community harmony, foster toxicity, or damages the reputation of the Game or Company. Decisions under this clause are final and may be made without prior notice at the Company’s sole and complete discretion.

14. WARRANTY DISCLAIMER.  THE GAME IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED. COMPANY DISCLAIMS ALL WARRANTIES INCLUDING, WITHOUT LIMITATION, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON‑INFRINGEMENT.

15. LIMITATION OF LIABILITY 
15.1 TO THE MAXIMUM EXTENT PERMITTED BY LAW, COMPANY SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING OUT OF OR RELATED TO THIS AGREEMENT OR THE GAME.
15.2 IN NO EVENT SHALL COMPANY’S TOTAL LIABILITY TO YOU EXCEED THE AMOUNT YOU PAID (IF ANY) FOR THE GAME DURING THE SIX MONTHS PRECEDING THE CLAIM.

16. FORCE MAJEURE.  Company shall not be liable for any delay or failure to perform resulting from causes beyond its reasonable control, including acts of God, war, natural disasters, internet failures, or labor disputes.

17. LAW; IMPORT/EXPORT RESTRICTIONS; INDEMNIFICATION. You are solely responsible for compliance with all applicable laws, regulations, rules, and legal requirements related to your use of the Game and Documentation, including but not limited to import, export, and re-export control laws and regulations. You agree not to download, install, access, use, export, re-export, or transfer the Game or Documentation (or any copies thereof) in violation of any applicable laws or regulations of the United States or any other jurisdiction. This includes, but is not limited to, compliance with all U.S. export control laws and economic sanctions administered by the U.S. Department of Commerce and the U.S. Department of the Treasury. You further agree not to: (a) access or use the Game in any country or region prohibited by applicable law or regulations, including those subject to U.S. government sanctions or embargoes; (b) provide the Game to any person, entity, or organization designated on a restricted or denied parties list maintained by the U.S. government or other applicable authorities. By accepting this Agreement, you represent and warrant that you are not located in, under the control of, or a national or resident of any country or region subject to such restrictions, nor are you a person or entity named on any such list. You agree to indemnify, defend, and hold harmless Company from and against any and all claims, losses, liabilities, damages, expenses, and costs (including reasonable attorneys’ fees) arising from or related to your breach of this provision or any violation of applicable laws or regulations.

18. TITLE. You agree that Company owns and holds all right, title, and interest to the Game and any Documentation, and all subsequent copies thereof regardless of the form or media. Furthermore, all title, ownership rights, and intellectual property rights in the Game and any Documentation shall remain with Company, including all corrections, enhancements, or other modifications made thereto. The Game and any Documentation are protected by copyright and other intellectual property laws and by international treaties. All rights not expressly granted to You under this Agreement are reserved by Company.

19. LIMITED WARRANTY. Company's sole liability for any breach of this warranty shall be, in Company's sole discretion: (a) to replace any defective Game; (b) to provide advice on achieving substantially the same functionality as described in any Documentation, if practicable; or (c) if the above remedies are impracticable, to refund the license fee you paid for the Game. Repaired, corrected, or replaced Game and Documentation shall be covered by this limited warranty for the period remaining under the warranty that covered the original Game.
You must notify Company of any problem with the Game during the warranty period and provide evidence of the date you purchased or obtained the Game license to be eligible for this warranty. Company will use reasonable efforts to repair, replace, advise, or refund, as applicable, within thirty (30) days of being notified.
This warranty is void if: (a) You modify the Game during the warranty period; (b) the Game is subjected to accident, abuse, or improper use; or (c) you violate the terms of this Agreement.
THIS IS A LIMITED WARRANTY, AND THE WARRANTY SET FORTH IN THIS AGREEMENT IS THE ONLY WARRANTY MADE BY COMPANY. COMPANY MAKES NO OTHER WARRANTIES, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, OR NON-INFRINGEMENT. GIVEN THE EARLY ACCESS STATUS OF THE SOFTWARE, THE ENTIRE RISK ARISING OUT OF USE OR PERFORMANCE REMAINS WITH YOU. NO DEALER, AGENT, OR EMPLOYEE OF COMPANY IS AUTHORIZED TO MODIFY THIS WARRANTY.
Any warranties provided by law shall only apply to the extent they cannot be excluded or limited by this Agreement.

20. DISPUTE RESOLUTION, ARBITRATION AGREEMENT, AND CLASS ACTION WAIVER.
PLEASE READ THIS ARTICLE CAREFULLY BECAUSE IT AFFECTS THE USER'S RIGHTS. BY AGREEING TO BINDING ARBITRATION, THE USER WAIVES THE RIGHT TO LITIGATE DISPUTE (DEFINED HEREINAFTER) THROUGH A COURT AND TO HAVE A JUDGE OR JURY DECIDE THE USER'S CASE.
20.1 All disputes, claims, or controversies arising out of or relating to the Terms or the relationship between the user and the company ("Dispute") shall be determined exclusively by binding arbitration. However, the Dispute does not include any claim with respect to the infringement, protection, or validity of intellectual property rights or a claim brought in small claims court.
20.2 The user agrees that the Dispute shall be resolved as the following procedures:
The user shall provide the company with the written notice ("Notice") regarding the Dispute by mail and email to the company at the address stated in Article III in order to resolve the Dispute through the company's customer center. Such Notice shall state the information including but not limited to the name, address, and contact information of the party giving it, the facts giving rise to the Dispute, and a proposed solution. If the user and the company do not reach an agreement to resolve the Dispute within 30 days after the Notice is received, the user may commence an arbitration proceeding.
The arbitration shall be administered by the International Court of Arbitration of the International Chamber of Commerce ("ICC") in Singapore under the Rules of Arbitration of the International Chamber of Commerce ("ICC Rules") in effect at the time of filing for the arbitration. The ICC Rules are available at https://iccwbo.org/dispute-resolution/dispute-resolution-services/arbitration/rules-procedure/2021-arbitration-rules/.
THE USER AGREES THAT ANY AND ALL ARBITRATION SHALL BE CONDUCTED ONLY ON AN INDIVIDUAL BASIS AND NOT ON A COLLECTIVE, CONSOLIDATED, OR REPRESENTATIVE CLASS ACTIONS. THE USER ACKNOWLEDGES AND AGREES THAT THE USER IS WAIVING THE RIGHT TO PARTICIPATE AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS OR REPRESENTATIVE ACTION TRIED OR CHALLENGED BY A JURY.
20.3 All disputes in relation to this contract must be raised in the binding arbitration process within 1 year.
20.4 The 1 year period starts from the time when the company receives the user's Notice. Raising Disputes is permanently forbidden if the Dispute is not raised within 1 year.
20.5 This Agreement and any Disputes shall be governed by and construed in accordance with the law s of Singapore, without regard to its conflict of laws principles

21. SEVERABILITY.  If any provision of this Agreement is held unenforceable, the remaining provisions shall remain in effect.

22. ENTIRE AGREEMENT & AMENDMENT.  This Agreement constitutes the entire agreement between you and Company regarding the Game and supersedes all prior agreements. No modification by you will be effective unless signed by an authorized representative of Company.

23. ACKNOWLEDGEMENT. By downloading, installing, or using any part of this Game, you indicate that you have read this Agreement, understand it, and agree to be bound by its terms and conditions.

24. CONTACT INFORMATION.
For customer support, please contact: [email protected].

Effective Date: January 29, 2026
________________________________________

The Midnight Walkers – Global Privacy Policy

1. Introduction
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. In particular, we process your personal data in accordance with GDPR principles, including lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality. By accessing or using the Game, you acknowledge that you have read and understood this Policy.

2. Data We Collect
We collect the minimum personal data necessary to operate the Game and provide our Services.
(1) Information you provide directly
1. Email address, account name, nickname, and Steam ID/profile name
2. Country, preferred language, and date of birth
3. For event participation: name, address, phone number, shipping information, and tax details
4. For customer inquiries: email address, inquiry details, and any attached files

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

(3) Information from third parties
1. Steam ID and nickname from Valve Corporation (Steam) for account management
2. Payment and community-related information managed under Steam’s Privacy Policy

3. Legal Grounds for Processing
We process your data based on the following legal grounds:

1. Performance of a contract: to provide and operate the Game and related Services.
2. Compliance with legal obligations: to meet requirements under applicable laws (tax, consumer protection, export control, etc.).
3. Legitimate interests: to ensure game security, improve the Game, and maintain fair gameplay, provided that such interests do not override your fundamental rights and freedoms.
4. Consent: where required, we will ask for your explicit consent (e.g., marketing communications). You may withdraw consent at any time.

4. How We Use Your Data
We use the collected data for the following purposes:

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

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

Customer Support
1. Data: Email address, nickname
2. Retention Period: 3 years
3. Legal Basis: Consumer Protection Act

Event Participation
1. Data: Name, address, phone number
2. Retention Period: Until purpose fulfilled

Contract or Withdrawal Records
1. Data: User identification data, consent history
2. Retention Period: 5 years
3. Legal Basis: E-Commerce Act

Payment and Supply Records
1. Data: Purchase and transaction information
2. Retention Period: 5 years
3. Legal Basis: E-Commerce Act

Dispute Resolution Records
1. Data: Inquiry details, email
2. Retention Period: 3 years
3. Legal Basis: E-Commerce Act

Access Logs
1. Data: IP address, connection records
2. Retention Period: 3 months
3. Legal Basis: Telecommunications Privacy Act
After the retention period ends, data will be securely deleted or anonymized using technical measures (erasure or destruction).

6. International Data Transfers 
We may transfer your data to trusted service providers located outside your country or region to support the operation of the Game.

Valve Corporation (Steam)
1. Purpose: Game distribution and account authentication
2. Location: United States
3. Retention: Until Service termination

Amazon Web Services, Inc.
1. Purpose: Cloud hosting and data storage
2. Location: United States / Singapore
3. Retention: Until Service termination

Shenzhen Anti-Cheat Expert Co., Ltd. (ACE)
1. Purpose: Anti-cheat detection and security services
2. Location: China 
3. 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.

7. Your Data Protection Rights
Under applicable laws, you have the following rights regarding your personal data:
1. Right of access – You can request copies of your personal data.
2. Right to rectification – You can request correction of inaccurate or incomplete data.
3. Right to erasure (“Right to be forgotten”) – You can request deletion of your data under certain conditions.
4. Right to restrict processing – You can request limitation of how we use your data.
5. Right to object – You can object to our processing based on legitimate interests.
6. 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 [email protected].

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:
1. Right to know what personal data we collect
2. Right to request deletion of personal data
3. Right to opt out of data sharing for marketing purposes
4. Right to non-discrimination for exercising privacy rights

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

1. Keep you signed in
2. Remember preferences and language
3. 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:
1. Chrome: Settings → Privacy and Security → Cookies and other site data
2. Edge: Settings → Cookies and Site Permissions → Manage and delete cookies

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

1. Access control and encryption
2. Secure servers and firewalls
3. Anti-virus and intrusion prevention systems
4. 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.

10. Children’s Privacy
The Game and Services are not intended for users under the age of 16 (or the age required by local law in your jurisdiction) .
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 [email protected].

11. Data Protection Officer & Contact Information
We have designated a Data Protection Officer (DPO)  responsible for ensuring compliance with this Policy:
1. Name: Wonhyuk Rhee
2. Position: Business Director / Data Protection Officer (DPO)
3. Email: [email protected]

For questions or complaints, please contact the following authorities as well:
1. Korea Internet & Security Agency (KISA): privacy.kisa.or.kr / +82-118
2. Personal Information Dispute Mediation Committee: kopico.go.kr / +82-1833-6972
3. Cyber Bureau, Korean National Police Agency: cyber.go.kr / +82-182

12. Changes to This Policy
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.

Effective Date: January 29, 2026

________________________________________

The Midnight Walkers – Rules Of Conduct

1. General Principles
This Rules of Conduct (“Policy”) is established by Oneway Ticket Studio Co., Ltd. (“Company”) to define the fundamental standards that both the Company and players must comply with in relation to the services provided for The Midnight Walkers (“Game”).
The purpose of this Policy is to ensure consistent management of various situations that may arise during gameplay and to provide a fair and stable gaming environment for all players.
Any matters not explicitly stated in this Policy shall be handled in accordance with the Terms of Service and the laws of the Republic of Korea.

2. Changes to the Rules of Conduct
If the Company revises this Policy to improve service quality, the Company will announce the details of the changes, the effective date, and the reasons for the amendment at least seven (7) days in advance through the official community page[https://linktr.ee/themidnightwalkers]
However, for significant or unfavorable changes to players, notice will be given thirty (30) days in advance.
Please note that the Company will not be held responsible for any issues arising from a player’s failure to review the announced changes, to the extent permitted by applicable law.

3. Company Obligations and Responsibilities
3.1 The Company strives to eliminate misconduct defined in this Policy and makes every effort to ensure that players can enjoy the Game smoothly and fairly.
3.2 The Company will never ask for a player’s account password and is committed to the protection and management of personal information.
However, if government or judicial authorities request personal information in accordance with due process, the Company may provide such information to the requesting authority.
3.3 The Company receives all reports related to bugs or technical issues via the official support email and community and will promptly review and resolve them.
3.4 The Company, as a principle, does not intervene or arbitrate normal in-game activities or disputes between players.
3.5 If abnormal or unintended behaviors occur that seriously disrupt the Game’s operation or stability, the Company may temporarily restrict parts or all of the Game services.
3.6 If any individual or group’s actions interfere with the Game’s stable operation or violate this Policy, the Company may restrict service use in accordance with the Sanction Table outlined herein.
3.7 The Company reserves the right, at its reasonable discretion, exercised in good faith, to suspend, deny, or terminate access to all Services (including account creation, login, and community participation) with or without prior notice, where reasonably necessary if the Company reasonably determines that an individual or group:
    (a) is likely to cause serious discord, toxicity, or controversy that harms community harmony or safety;
    (b) damages or threatens to damage the Game’s or Company’s reputation or brand value;
    (c) engages in or promotes any form of External Misconduct as defined in the EULA.

Such measures shall be determined at the Company’s reasonable discretion, taking into account the severity, intent, and impact of the conduct.
Appeals regarding these actions may be submitted once in writing (via email) within seven (7) days of the sanction.
The Company may also reference publicly available materials such as law enforcement records, media reports, or disciplinary cases from other platforms or games when evaluating a player’s conduct.

4. Player Obligations and Rights
4.1 Players must understand and comply with the Terms of Service and this Rules of Conduct.
4.2 All rights to information generated during gameplay (such as characters, items, and in-game currency) belong to the Company.
Players are granted only the right to use such information while using the Service.
4.3 Players who suffer unfair treatment or damage while using the Game may submit a complaint or request correction through appropriate channels.
Players also have the right to report violations by other players and request enforcement of this Policy.
4.4 Players are responsible for reviewing and understanding official notices or information provided by the Company.
The Company is not responsible for any loss resulting from failure to do so.
4.5 Players may not engage in any commercial or profit-making activities using the Game without prior written consent from the Company.
4.6 Players may not copy, reproduce, modify, translate, publish, or otherwise use information obtained through the Game, nor provide it to others, without prior written permission from the Company.
4.7 Players must not spread false or misleading information that can cause confusion among other players.
4.8 If a player discovers any vulnerabilities (bugs, system errors, unauthorized programs, etc.), the player must report them to the Company and refrain from sharing or exploiting them.
Failure to report and subsequent misuse or distribution of such vulnerabilities will be considered intentional misconduct and may result in sanctions under this Policy.
4.9 Players may contact the Company regarding any inquiries, suggestions, or requests related to the Game at:

Customer Support Email: [email protected]

5. Policy on Misconduct and Prohibited Behavior
The Company has established the following rules to ensure a fair and enjoyable gaming environment for all players.
All players must comply with the rules below while using the Game. Violations may result in disciplinary action as defined in Section 6.

5-1 Use of Unauthorized Programs and Hardware Devices
Use of any unauthorized or unapproved software, scripts, macros, or hardware devices (including programmable mice, modified controllers, etc.) that provide unfair advantages or interfere with normal gameplay is strictly prohibited.
Players found using such tools may face permanent suspension, and the hardware involved may also be permanently blocked.
Developing, advertising, selling, or distributing such tools may be referred to law-enforcement authorities.

5-2 Unauthorized Modification of Client, Server, or Data
Altering or tampering with any part of the Game client, server, or data packets without authorization constitutes an attack on the Game Service and violates copyright law.
Such conduct will result in permanent suspension.

5-3 Exploitation of Bugs or System Vulnerabilities
Exploiting bugs or errors to gain unfair advantages, or failing to report discovered issues through official channels, will result in sanctions.
All unfairly obtained items or currency will be revoked.
Distributing or sharing exploit methods is also subject to punishment.

5-4 Inappropriate Names
Creating or using names that are offensive, misleading, or socially unacceptable is prohibited, including:

    - Sexually explicit, obscene, or vulgar names
    - Names impersonating Company staff or partners
    - Names defaming religions, races, or organizations
    - Names infringing third-party trademarks or copyrights
    - Any variation of the above achieved by altered spelling or hidden characters

Such names may be changed or removed without notice, and disciplinary measures may be taken.

5-5 Use of Offensive or Abusive Language
The Company promotes a healthy gaming culture.
Players must refrain from using any language or behavior that insults, harasses, or offends others.
This includes:
    - Profanity, slurs, or obscene language
    - Sexually explicit expressions or actions causing discomfort
    - Hate speech targeting regions, religions, races, or disabilities
    - Threats or intimidation in-game or through chat
    - Any expression that may cause fear, disgust, or emotional harm

Abuse toward customer-support staff (verbal abuse, sexual remarks, or threats) may also result in restricted support access.

5-6 Chat Spamming
Posting excessive or repetitive messages that disturb other users’ chat experience may result in temporary chat restrictions or game access limitations.

5-7 Real-Money Trading (RMT)
Any attempt to trade or advertise in-game items, currency, or accounts for real-world money or goods is prohibited.
This includes using nicknames or custom lobbies for such purposes.
Violations will lead to permanent suspension.

5-8 Advertising or Promotion
Advertising or promoting products, services, or content unrelated to the Game or the Company is prohibited.
l commercial use of the Game for profit-making or marketing purposes is forbidden.

5-9 Gameplay Disruption
Players must not intentionally or repeatedly interfere with others’ gameplay.
Examples include:
    - AFK (Away From Keyboard): Remaining inactive for extended periods, harming teammates’ experience.
    - Intentional Leaving: Disconnecting or quitting games to disadvantage one’s team.
    - Collusion with Opponents: Providing information or advantages to the opposing team.

5-10 Teaming
Forming unofficial teams or colluding with other players outside the authorized game modes is prohibited.
Playing alongside users employing unauthorized programs for personal gain will be considered abnormal team formation and may lead to sanctions.

5-11 Team Killing
Intentional or repeated acts that harm teammates or interfere with normal team play are strictly forbidden and subject to penalties.

5-12 Harassment or Stalking
Continuously attacking or following another player with the intent to harass or disrupt their gameplay is prohibited.
Verified incidents will result in disciplinary action.

5-13 Personal Information Disclosure
Sharing or posting another player’s personal information without consent—by any means—is considered a serious privacy violation and will lead to permanent suspension.

5-14 Abuse (“Abusing” or Account Manipulation)
Engaging in activities such as account boosting, account sharing, paid proxy gameplay, or manipulating multiple accounts for personal gain constitutes abuse.
All illicitly obtained items or data will be confiscated, and permanent suspension may apply.

5-15 Account Theft or Unauthorized Access
Accessing or attempting to access another person’s account is strictly forbidden.
For security, the Company may apply account restrictions when suspicious activity is detected.

5-16 Account Trading or Selling
Trading, selling, or transferring accounts or in-game data without the Company’s written consent is prohibited and will result in sanctions.

5-17 AFK Farming
Remaining idle to gain in-game currency, items, or experience without actual participation is considered unfair play.
All improperly gained items or rewards will be removed, and penalties may apply.

5-18 Interference with Operations
Spreading false information, impersonating employees, abusing support channels, or encouraging rumors that disrupt normal operations may result in permanent suspension depending on severity.

5-19 Abnormal Gameplay and Undefined Misconduct
Any conduct not explicitly listed here but which violates applicable laws, harms the Service, or negatively affects other players or community order will be reviewed and sanctioned accordingly.

6. Sanctions for Misconduct
6-1 The sanction system exists to protect fair gameplay and ensure the stability of the Service.
6-2 Players who commit prohibited acts under this Policy may be restricted from using the Game without prior notice.
6-3 Repeated or severe violations may result in permanent suspension.
6-4 Players sanctioned for misconduct may also be excluded from leaderboards or ranking displays.

[Misconduct and Penalties]

Use / advertisement / development / distribution of unauthorized programs or hardware
    - Maximum Penalty: Permanent ban

Investigation of abnormal data
    - Maximum Penalty: 3-day suspension

Unauthorized modification of client / server / data
    - Maximum Penalty: Permanent ban

Exploiting bugs or system vulnerabilities (severe impact)
    - Maximum Penalty: Permanent ban

Use of offensive language
    - Maximum Penalty: 30-day suspension

Unauthorized promotion or advertising
    - Maximum Penalty: Permanent ban

Inappropriate names
    - Maximum Penalty: 30-day suspension

Abnormal team formation
    - Maximum Penalty: Permanent ban

Team killing
    - Maximum Penalty: Permanent ban

Gameplay interference
    - Maximum Penalty: 30-day suspension

Stalking or harassment
    - Maximum Penalty: Permanent ban

Personal information leak
    - Maximum Penalty: Permanent ban

Abuse (account manipulation, boosting, etc.)
    - Maximum Penalty: Permanent ban

Account theft / unauthorized access
    - Maximum Penalty: Permanent ban

AFK (idle farming)
    - Maximum Penalty: Permanent ban

Interference with operations (false reports, impersonation, rumors)
    - Maximum Penalty: Permanent ban

Abnormal gameplay
    - Maximum Penalty: 30-day suspension

Attempted real-money trading
    - Maximum Penalty: Permanent ban

6-5 Exploiting bugs or system vulnerabilities to gain in-game resources or currency may disrupt game balance and lead to permanent suspension.
6-6 While the Company generally applies the highest penalty listed for each offense, the severity or frequency of misconduct may result in a harsher or lighter sanction.
6-7 To protect honest players, the Company may block game execution on specific hardware devices used for cheating.
6-8 All items, currency, and data gained through misconduct may be deleted, and in severe cases, the entire account may be removed.
6-9 If multiple accounts are created on the same device or IP address for unlawful purposes, the Company may apply restrictions to all related accounts and hardware.

7. Recovery Policy
7-1 The Company cannot provide compensation or recovery for any losses resulting from the player’s own negligence, misunderstanding of the Game System, this Rules of Conduct, in-game notices, or information published on the official website.
Players are responsible for familiarizing themselves with all announcements and policies provided by the Company.

8. Bonus / Gift Code Policy
8-1 Provision of Codes
The Company may, directly or through its partners, provide bonus or gift codes (“Codes”) that allow players to access in-game content such as outfits, weapon skins, or other items (“In-Game Content”).
A Free Code refers to a Code provided without payment for promotional or marketing purposes. Codes obtained through participation in events, tournament attendance, or other promotional activities are considered Free Codes.
A Paid Code refers to a Code provided to players in exchange for payment for the purpose of sale.

8-2 Types of Codes Provided
The Company may provide both Free Codes and Paid Codes that grant players access to In-Game Content such as costumes, weapon skins, or other digital items.

8-3 Code Registration and Restrictions
Players may redeem Codes on their own accounts to access the corresponding In-Game Content.
The sale or transfer of Codes to another person is strictly prohibited under all circumstances.

8-4 One-Time Use and Non-Refundability
Codes can be redeemed only once.
Once registered, a Code cannot be reused, returned, or refunded under any circumstances.

8-5 Validity of Free Codes
Free Codes are valid for three (3) months from the date of issuance.
Expired Codes cannot be redeemed.

8-6 Validity of Paid Codes
Paid Codes are valid for five (5) years from the date of issuance.
Players may redeem a Paid Code within five years of issuance.
If a Paid Code expires within five years due to a fault of the Company, the player may request an extension of the validity period for up to five years from the date of issuance.
Free Codes cannot be extended.

8-7 Liability Disclaimer
The Company shall not be held responsible for any losses or damages incurred by players or third parties arising from the sale, transfer, or expiration of Codes.

8-8 Partner-Issued Codes
For Paid Codes issued or distributed through partner companies, all matters related to refunds, inquiries, and validity periods shall be governed by the partner’s own terms and conditions.

9. Cash Usage Policy
In-game currency (“Cash”) refers to virtual funds used to purchase goods or services provided by the Company within the Game.

9-1 Definition of Paid Cash
“Paid Cash” refers to Cash purchased through monetary payment, or Cash included in a bundle product.
Players may withdraw or cancel purchases of Paid Cash in accordance with the Company’s Terms of Service (see Section 9-7).

9-2 Definition of Free Cash
“Free Cash” refers to Cash obtained without payment, such as through in-game events, Survival Pass missions, or other promotional activities.
Free Cash cannot be refunded or withdrawn under any circumstances.

9-3 Cash Charging
Cash may be charged via third-party payment service providers.
Players can purchase Cash in units or amounts determined by the Company.

9-4 Purchase of In-Game Items
Players can purchase in-game items within the amount of Cash they possess.
Once a purchase is made, the corresponding amount of Cash will be immediately deducted from the balance.

9-5 Validity Period of Paid Cash
Paid Cash is valid for five (5) years from the date of purchase.

9-6 Validity Period of Free Cash
Free Cash is valid for three (3) months from the date of acquisition, unless otherwise adjusted at the Company’s discretion.

9-7 Withdrawal and Refund Policy
Withdrawal of subscription or refund for Paid Cash shall follow the Terms of Service.
Free Cash is not eligible for withdrawal.
Items purchased with Paid or Free Cash may be canceled within fourteen (14) days if they remain unused.
However, withdrawal or refund may be restricted under the following circumstances:
9-7-1 If the player’s account is suspended due to serious misconduct — including violations of the Terms of Service, Rules of Conduct, or relevant laws that significantly affect the Game.
9-7-2 If the Terms of Service, this Policy, or the specific purchase conditions define the product or service as non-refundable.
9-7-3 If the Cash or item was granted through participation in or as a prize from events, promotions, or giveaways.

9-8 Fraudulent Payment or Use
If any player forges, alters, steals, or illegally obtains or uses payment information to purchase or use Cash, the Company will take disciplinary measures, which may include:

    - Account suspension or permanent ban,
    - Deletion of all in-game assets acquired through the fraudulent transaction, and
    - Legal action in accordance with applicable laws.

10. Nothing in this Rules of Conduct shall limit or exclude any rights that cannot be limited or excluded under applicable law.

Effective Date: January 29, 2026