Privacy Policy（隱私政策）

Last Updated（最後一次更新）: 10/2021

You acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy, you must not use NSN GAMES Services. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.

At NSN GAMES, we know your privacy is very important to you, so please take the time to carefully read our privacy policy. Our policy is designed to help you understand:

1. What information do we collect about you;
2. How will we use the information about you;
3. Who do we share your information with;
4. How long do we keep hold of your information;
5. How can I exercise my rights over my information;
6. Dispute Resolution;
7. How will we notify you of changes;
8. Contact Information.

This privacy policy applies to all NSN GAMES services that directly reference or link to this policy, but does not apply to NSN GAMES services that have separate privacy policies that do not incorporate this policy.

SECTION 1: WHERE WE ARE A DATA CONTROLLER

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:

• Information you provide us:

  • When you register for the Game (including your nominated nickname, or custom accounts and information we import from your connected social media account (WeChat, Facebook) in order to set up your profile, including your name as it appears on your social media profile).
  • When you log in as a ‘guest’ in order to use the Game (your nickname).
  • When you participate in a survey in the Game (in which case we will process the information you provide to us as part of the survey).
  • Information you provide when seeking help from us such as your name, telephone number, and records of the issues you experience.
  • Billing information, such as your name, payment card number, and payment account details.

• Information we collect about you:

  • We automatically collect certain data from you when you use the Game, including your IP address and device information (such as application version, network type, OS) and information regarding your use of the Game, such as date and time stamps of actions. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.

• Information you generate and display in the course of using the Game Services:

  • You may provide additional information as part of your profile (such as gender). You may also provide or generate information when you communicate with other users in the Game (e.g., chat log data, chat content).

• Data we collect from our partners:

  • Data we receive if you link a third-party tool with the Service (such as WeChat, Facebook).
  • Demographic data (such as to determine the coarse location of your IP address).
  • Data to fight fraud (such as refund abuse in games or click fraud in advertising).
  • Data from platforms that the games run on (such as to verify payment).
  • Data for advertising and analytics purposes, so we can provide you a better Service.

• Cookies:

  • We use cookies and other similar technologies (e.g. web beacons, log files, scripts, and eTags) (“Cookies”) to enhance your experience using the Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the Game) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed.

2. How we use your personal information

We will use the information in the following ways:

Personal Information	Use
Nickname	We use this information to create your account for the Game in accordance with your request.
Social Connect Information: - Facebook Name, Facebook ID	We use this information to: Create your account for the Game in accordance with your request; Share in-game photos on Facebook at your request.
Generated Open ID	We generate this and use this to store your Game data (including level and progress) with your profile.
Game Play Statistics (Level, Score/s)	We use this information to provide you with feedback and information about your gameplay and progress.
IP Address	We use this information to improve our services, including the functionality of the Game.
Device ID, Device Information	We use this information to: Improve our services, including the functionality of the Game; For security and verification purposes; Identify and address bugs and assess game function for optimization; Combat users registering for multiple accounts.
Advertising ID	If you click on a link that advertises the Game, we store the Advertising ID for that advertisement with your profile.
Chat Data	If you enable chat services (audio or text) then we will process such data in order to deliver your messages to other users.
Transaction Records: payments on Google Play or iOS App Store	We use this information to maintain a record of your transaction history.
Customer Support Ticket ID & User Communications with Support	We use this information to: Improve our services; Provide troubleshooting such as addressing and remediating technical issues and bugs.
Security-Related Information	We use this information to: For security and verification purposes; Identify and address bugs and assess game function for optimization; Solve game crashes and optimize compatibility of devices with the game; Combat users registering for multiple accounts.
Survey Information and content of survey responses	Stored for: (a) If you provide your email as part of the survey, up to 6 months (in order for us to follow up with you) and then the data is anonymized; (b) If you do not provide your email as part of the survey, up to 1 month and then the data is anonymized.

Analyze, Profile, and Segment

In all of the above cases and purposes, we may analyze, profile, and segment all collected data.

Legal Basis for Processing

If you are a resident of the European Union, we rely on a number of legal grounds to process information about you. For example, we will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and where we have a legal obligation to process your information. For example, we rely on our legitimate interests to serve targeted marketing and on contractual necessity to process information when you create an account. To learn more about the legal grounds on which we rely to process your information for any particular purpose, please contact us via the options in the Contact & Complaints section below.

How We Share Your Personal Information

We share your personal information with selected third parties in and outside your country, including:

• Other players and users: Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities, and read the messages you have posted.
• Partners working for NSN GAMES: NSN GAMES has partners to perform services for us. These partners process your data only at and according to NSN GAMES’s instructions to provide the Service, such as hosting, player support, advertising, analytics, and fraud prevention.
• Other companies and public authorities: In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests. We may also disclose your data based on your consent, to comply with the law, or to protect the rights, property, or safety of us, our players, or others.
• Related group companies (NSN GAMES (Hong Kong) Limited): We share your personal information to operate the Game Services.
• Law enforcement agencies, public authorities, or other judicial bodies and organizations.
• A third party that acquires all or substantially all of us or our business: We will disclose information to a third party in the event that we sell or buy any business or undergo a merger. In such transactions, user information may be among the transferred assets.

Data Retention

We will retain your personal information as described below (except if otherwise required to be retained by applicable law).

Personal Information	Use
Nickname	We use this information to create your account for the Game in accordance with your request.
Social Connect Information: WeChat	Stored for the lifetime of your use of the Game (i.e., until account deletion in accordance with your request or you revoke access) and then deleted within 30 days.
Social Connect Information: Facebook	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Game Play Statistics (Level, Heroes, Score/s)	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Chat Communications (Audio message)	Stored for 7 days on our servers and deleted automatically upon expiry of such period.
Chat Communications (Text)	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 7 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
OpenID	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
IP Address	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Device ID, Device Information	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 30 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Advertising ID	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Transaction Records	Stored for the lifetime of your use of the Game (i.e., until account deletion in accordance with your request) and then for the duration of any retention periods for which such data must be retained in order to comply with our legal obligations.
Customer Support Ticket ID & User Communications with Support	Support data is deleted within 30 days of a lawful request from you for the erasure of such data (see the Erasure section of this privacy policy).
Security-Related Information	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 30 days.
Survey Information	Stored for: (a) if you provide your email as part of the survey, up to 6 months (in order for us to follow up with you) and then the data is anonymized; or (b) if you do not provide your email as part of the survey, up to 1 month and then the data is anonymized.

Personal Information is kept until the end of its life cycle (as set out in the retention policy above). When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws.

Section 2: Your Rights

This section (“Your Rights”) applies to users that are located in the European Economic Area only. You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please email us at wuzp@nsn592.com.

1. Access
   You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your Game account and by contacting wuzp@nsn592.com. If you believe we hold any other personal information about you, please email us at wuzp@nsn592.com.

2. Portability
   You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., certain survey information) or pursuant to our contract with you, as described in the section “How We Use Your Personal Information.” You have the right to receive this information in a structured, commonly used, and machine-readable format. You also have the right to request that we transfer that personal information to another party.
   If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

3. Correction
   You have the right to correct any personal information held about you that is inaccurate. You can access the personal information you have made available as part of your account by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please email us at wuzp@nsn592.com.

4. Erasure
   You can delete your account, or remove certain personal information, by logging into your Game account. If there is any other personal information you believe we process that you would like us to erase, please email us at wuzp@nsn592.com.
   You may request that we erase the personal information we hold about you in the following circumstances: