OUR COMMITMENT TO PRIVACY
TYPES OF INFORMATION WE COLLECT
Generally speaking, when you use our Digital Properties and when you communicate with us via the Digital Properties, we will not collect personal information about you unless you provide us that information voluntarily. You should be aware that when you visit our Digital Properties, we collect certain information for various business purposes, including ensuring the functionality of the Digital Properties, improving the user experience, fighting fraud and abuse, and analyzing usage data related to our Digital Properties. This data helps us to analyze and improve the usefulness of the information we provide on the Digital Properties, as well as our products and services. More specifically, the types of information we collect from the Digital Properties is as follows:
- User-Supplied Information. When you choose to provide it, we collect personal information such as your name, address, telephone number, financial information, player profile information (including player tag and password), profile information (such as a profile photo), email address, messages and other content submitted by you in using the Digital Properties (such as chat logs and player support tickets) and other information you choose to give us, in connection with services and products available or described on the Digital Properties.
- Automatically Collected Information. We may collect IP addresses, approximate location data (as derived from your IP address), data about your device (such as such as device name and operating system, browser type and language, internet service provider, and mobile carrier), and usage data (such as gameplay data, in-app purchases, and interactions with other users of the Digital Properties), in order to operate the Digital Properties and improve the user experience. The Digital Properties also track the sites within our Digital Properties that you view, the date and time you view those sites and various other statistics.
- Cookies. Like most businesses operating mobile applications and/or websites, we may track your visits to our Digital Properties by giving you HTML “cookies” when you enter. Cookies are pieces of information transferred to your device’s hard drive or shared with your device’s temporary memory for recordkeeping purposes. Cookies are not computer programs and have no ability to read data residing on your device or instruct it to perform any step or function. By assigning a unique data element to each visitor, the Digital Properties can recognize repeat users, track usage patterns and better serve you when you return to a particular Digital Property. For example, a cookie can be used to store your preferences for certain kinds of information or to store a password so that you do not have to input it every time you visit one of our Digital Properties. Cookies also help us to collect anonymous click-stream data for tracking visitor trends and patterns. Most browsers are initially set up to accept cookies. If you prefer, you can reset your browser either to notify you when you have received a cookie or to refuse to accept cookies. You should understand that certain areas of our Digital Properties may not function properly if you set your browser not to accept cookies.
- Third Party Partner Information. NPG also uses third-party partners, such as social media sites, data analytics providers, and advertiser networks to supplement the information we have about you. Such information may include data we receive if you link the Digital Properties to a third party tool (such as Facebook or Google), data from payment providers and verification services, and data used to fight fraud (such as refund abuse or click fraud). Our advertising partners may use this data (and similar data collected from other services) for purposes of delivering targeted advertisements to you when you visit third-party services within their networks. These partners may operate under their own privacy policies.
WAYS WE USE INFORMATION
NPG collects and uses your personal information to operate the Digital Properties and deliver the services you have requested, including creating accounts, facilitating gameplay, delivering messages about our Digital Properties, and delivering products and services you request. NPG also uses your personally identifiable information to inform you of other products or services available from NPG. We may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered. By providing personal information into any of the above areas, you grant us permission to use such information for our business purposes, including without limitation contacting you regarding product or service offers or customer survey requests, and you grant us permission to securely transmit your personal information to third parties to fulfill our business purposes. Further, we may
contact you about selected products, services, companies and events that we think may interest you or to contact you regarding your requests, questions, comments or other information you have provided. NPG does not sell, rent or lease its customer lists to third parties. NPG may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, NPG may share data with trusted partners to help us perform statistical analysis, send you in-app communications, email or postal mail, provide customer support, moderate the Digital Properties and user communications, process payments or complete transactions. All such third parties are prohibited from using your personal information except to provide these services to NPG, and they are required to maintain the confidentiality of your information. If you later decide you do not want your information to be used in these ways, please let us know through the opt-out procedures described below.
NPG keeps track of the sites our customers visit within the Digital Properties in order to determine what NPG products and services are the most popular and to deliver, target, and improve advertising and the functionality of the Digital Properties. This data is used to deliver customized content and advertising within the Digital Properties to customers whose behavior indicates that they are interested in a particular subject area.
By providing the personal information of a person other than yourself or that of an entity into any of the above areas, you are solely responsible for obtaining from such person or entity any and all required rights, releases, consents, clearances, licenses, and other authorizations necessary to exploit and otherwise use their information (the “Clearances”). By submitting such information, you represent and warrant to NPG that all required Clearances have been obtained and NPG is entitled to rely on the same.
Some of our Digital Properties include social features as a core component of gameplay. Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through the Digital Properties, including public message boards and/or social media channels, this information may be collected and used by others. Other users of the Digital Properties may see your profile data, ingame activities, and messages you post on the Digital Properties.
We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of NPG, our players, or others.
NPG encourages you to review the privacy statements of websites or mobile applications you choose to link to from the Digital Properties so that you can understand how those websites and applications collect, use and share your information. NPG is not responsible for the privacy statements or other content on websites and mobile applications outside of the Digital Properties.
HOW WE DISCLOSE INFORMATION WE COLLECT
NPG may disclose your information to our affiliated companies as well as to third parties that provide services to us as permitted by law, unless we are otherwise notified by you through the opt-out procedures described below. NPG may also disclose your information: (a) in response to requests from local, state or federal law enforcement officials; (b) in response to any judicial, administrative, or similar proceeding such as a subpoena; (c) when required by law; (d) to protect and defend our rights, business or property; (e) in special circumstances including in connection with a fundamental corporate structure or ownership change or in response to a physical threat (actual or perceived) to an individual; (f) to register or verify your account on the Digital Properties; (g) to communicate with you regarding the status of your account or provide information otherwise related to your use of the Digital Properties or (h) to enforce
HOW WE PROTECT YOUR INFORMATION
You should be aware that, in general, information sent through the Internet is not secure. NPG, however, takes commercially reasonably steps to secure your personal information from unauthorized access, use or disclosure. NPG secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. That said, however, you should be aware of the following:
- Information Security. NPG does not warrant the security of your information. However, we utilize encryption and/or security software to safeguard the confidentiality of personal information we collect from unauthorized access or disclosure and accidental loss, alteration or destruction.
- Evaluation of Information Protection Practices. Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the security, confidentiality and quality of information.
- Employee Access to Your Information. In general, our business practices limit employee access to personal information and limit the use and disclosure of such information to authorized persons, processes and transactions.
- Data Retention. NPG may retain your data for as long as your account is active or as needed to provide you services in the Digital Properties. We may for example periodically de-identify dormant user accounts, and we may regularly review and de-identify unnecessary data. If you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
CHOICE/OPT-OUT – INFORMATION USES
You may opt out at any time and for any reason. Opting out may affect the functionality of certain Digital Properties. You can opt-out of personalized advertising on mobile applications by checking the privacy settings of your device and turning off “Allow Apps to Request to Track” or selecting “Limit Ad Tracking” (Apple iOS) or “Opt-out of Interest Based Ads” (Android).
You can also opt out from personalized in-game offers through the options provided in the game settings, where applicable.
YOUR OTHER RIGHTS
In addition to the other rights listed here, you also have the right to obtain a copy of your data (for which we may charge a small fee), correct your data, request that we delete your data, and restrict how NPG uses, process, or shares your data. You can always withdraw consent you have previously given to us. We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may also contact your local data protection authority, if applicable.
If you wish to exercise any of your data subject rights described above, please use the support options described in “How To Contact Us” below. NPG will respond to all requests in accordance with applicable laws. To protect your privacy, we may also take additional steps to verify your identity before fulfilling your request, such as by requesting you provide us a purchase receipt or other account information, asking you to link your email address with your game account, or asking you to answer questions regarding your activities on our Digital Properties. Once you have verified your identity, you may also designate an authorized agent to exercise your rights on your behalf by providing the agent’s contact information to our customer support staff, as required by applicable law.
We will not discriminate against you for your exercise of these rights.
At NPG, we are sensitive to the need to protect the privacy of children who use the Internet. NPG does not specifically target any products or services on any Digital Property to children under 13 years old. Further, we will not knowingly collect personal information from children under the age of thirteen (13) consistent with the Children’s Online Privacy Protection Act. Individuals under the age of 13 should only use the Digital Properties with the permission and under the supervision of a parent or guardian. We may limit access to certain features on the Digital Properties for individuals under the age of thirteen (13). Individuals under the age of thirteen (13) should not attempt to provide any personal information on any of the Digital Properties. If we become aware that a child under the age of thirteen (13) has provided personal information to us through our Digital Properties, we will delete it from our files. If you are a parent or legal guardian of someone under the age of thirteen (13) whom you believe has submitted personal information to us, please contact us here, and we will take appropriate steps to remove such information from our files within three business days.
Please note that the Digital Properties may contain links to third-party content providers that collect information from children under the age of 13. NPG has no control over such content providers and is not responsible for the privacy practices or the content of other websites or mobile applications. Because the Internet and mobile applications offer open access to a wide range of information, it is important that parents supervise and prevent access to inappropriate content.
ELECTRONIC COMMUNICATIONS FROM NPG
You have the right to withdraw your consent to receive Electronic Communications from NPG; however, you acknowledge and agree that NPG has the right to restrict or terminate your access to certain aspects of the Digital Properties if you withdraw your consent to receive Electronic Communications. If you wish to withdraw your consent, either click the unsubscribe link from the NPG email you received or follow the opt-out instructions sent via text.
RELEASE AND LIMITATIONS
BY USING THE DIGITAL PROPERTIES, YOU RELEASE, WAIVE AND DISCHARGE NPG FROM ANY AND ALL LIABILITY RELATED TO, AND AGREE THAT NPG IS NOT RESPONSIBLE FOR: (I) ANY DISCLOSURE OF PERSONAL INFORMATION MADE BY YOU TO A THIRD PARTY THROUGH YOUR USE OF THE DIGITAL PROPERTIES; (II) ANY DISCLOSURE OF PERSONAL INFORMATION OBTAINED ILLEGALLY FROM US; OR (III) ANY ACCIDENTAL DISCLOSURE OF PERSONAL INFORMATION MADE BY US.
HOW TO CONTACT US
Effective Date: November 21, 2022