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DATE LAST MODIFIED: 8 January 2025
At NINE TWENTY TECH LTD ("we," "us," or "our"), protecting your privacy and securing your
information is our top priority. This Privacy Policy explains in detail how we collect, use, and manage
information related to you when you access our site or play a game created by an independent game
developer using our services.
Personal Information You Provide Directly in the Developer Game: We may gather the following types of
personal information that you input during your gameplay of a Developer Game:
· Contact Information: This includes details such as your first name, surname,
email address, residential address, and mobile or other phone numbers. This information is crucial for us
to communicate with you effectively regarding your gaming experience, provide updates, and address any
concerns or inquiries you may have. For example, we may use your email address to send you important
notifications about game updates, maintenance schedules, or special events. Your residential address may
be used for shipping physical merchandise related to the game, if applicable.
· Personal Attributes: We may collect personal information like your gender, age,
age range, or even your image. Additionally, account login details such as your username, password, and
pictures associated with your profile are also gathered. This data helps us personalize your gaming
experience and ensure the security of your account. For instance, knowing your age can allow us to
recommend age-appropriate games or features. Your username and password are used to authenticate your
identity when you log in, and your profile picture adds a personal touch to your in-game presence.
· Communication Data: Information sent bilaterally or within a small group using
email, post, or other methods of communication. This could include in-game messages, group chat logs, or
any correspondence related to the game. In-game messages can enhance your social interaction with other
players, while group chat logs may be used for moderation purposes to ensure a positive gaming
environment.
· Third-Party Information: We may obtain information from a third party, such as
a site or platform provider, about your use of or interest in our services. This could provide us with
insights into your preferences and help us improve our offerings. For example, if you have interacted with
our game on a third-party gaming platform, that platform may share information about your gameplay habits
or preferences with us, allowing us to better tailor our services to your interests.
· Location Information: Location information provided by a mobile or other device
interacting with one of our websites, or associated with your IP address (where legally permitted). This
allows us to offer location-based services, such as region-specific events or content. For example, if you
are in a particular city, we may offer you in-game events or promotions that are relevant to that
location. However, we respect your privacy and only use this information in accordance with the law and
with your consent, where required.
· Usage and Device Information: Activity, technical, and device information about
your use of our websites. This encompasses details like the content you view, the time and duration of
your visit on our websites, how often you use our services, how you first learned about our websites, your
preferences, and information about your interaction with the content offered through our websites. We also
collect your hardware model, device type, other unique device identifiers, operating system version,
browser type, and IP address. This data is used for analytics purposes, to optimize our services, and to
ensure compatibility with your device. For instance, we can analyze which game features are most popular
among users with a certain device type and optimize those features accordingly. We can also use this
information to troubleshoot technical issues that may be specific to your device or browser.
· Government Identifiers: In certain situations where required for tax or other
legal reasons, we may collect government identifiers such as your passport, driver's license, or social
security numbers. This is to comply with legal obligations and ensure the integrity of our operations. For
example, if you are eligible for certain tax benefits related to in-game purchases or winnings, we may
need to collect this information to process the appropriate documentation.
· Sensitive Information: We may collect sensitive information such as biometric
data, geolocation, drivers licenses, and financial information to meet our legal and regulatory purposes.
For example, if you engage in in-game purchases, we need to process payment information securely.
Biometric data, if used for authentication purposes, would be handled with the utmost care to protect your
privacy. Geolocation data can be used to enhance location-based services, but only with your explicit
consent and in compliance with privacy laws.
· We use your personal information to enable you to register for and access Developer
Games and update your profile information. This ensures that your gaming account is personalized and
secure. When you register, your provided details are used to create a unique account that is associated
with you. Your password is encrypted and stored securely to protect your account from unauthorized access.
Any changes you make to your profile information, such as updating your email address or display name, are
also managed using this personal information.
· We utilize your personal information to confirm that you are legally eligible
to access and play a Developer Game, or to use specific features and functionalities within the game,
based on the laws of your country or state. This helps us maintain a compliant and fair gaming
environment. For example, if a game has age restrictions or is only available in certain regions due to
legal requirements, we use your location and age information to ensure that you meet the necessary
criteria. If you are attempting to access a game that is restricted in your jurisdiction, you will be
notified and prevented from playing.
· We assist you in finding other players on Developer Games, for example, by
matching you with people whose details are saved in your phone contacts. This enhances the social aspect
of gaming and allows for more engaging interactions. By connecting you with friends or like-minded
players, we aim to create a more enjoyable and immersive gaming community. Your contact information is
used only for this purpose and is not shared with other players without your consent.
· We handle your payments and purchases, such as updating your account to reflect
any in-game transactions you make. This involves securely processing financial information and ensuring
accurate accounting of your purchases. When you make a purchase within the game, your payment details are
encrypted and transmitted to our payment partners using industry-standard security protocols. We keep a
record of your transactions to provide you with a history of your purchases and to handle any potential
disputes or refunds.
· We provide features and functionalities of the Developer Game, such as in-app
messaging, chat, gameplay performance records, and profile customization features. Your personal
information is used to tailor these features to your preferences and enhance your overall gaming
experience. For example, your in-app messaging preferences can be saved so that you receive notifications
in a way that suits you. Your gameplay performance records can be used to provide you with personalized
tips and strategies to improve your skills. Profile customization features rely on your personal
information to allow you to create a unique in-game identity.
· We offer support related to Developer Games. Additionally, we use your personal
information to measure the performance of our Services, identify and fix issues, and continuously develop
and improve the features and functionalities. We also utilize this data to test and develop new products
and services, ensuring that we stay at the forefront of the gaming industry. For instance, if we notice
that a particular feature is causing problems for a significant number of users with a certain device
type, we can use that information to investigate and resolve the issue. Your feedback and usage data can
also influence the development of new games or features that better meet the needs and preferences of our
users.
· We communicate with you and address any comments or complaints you submit. We
send you service-related communications, like purchase confirmations. Moreover, we send you marketing
materials, including emails, newsletters, and other communications in line with your preferences. This
helps us keep you informed about new games, updates, and promotions.
· We maintain the safety and security of our Services by using your personal
information to detect and prevent fraud, abuse, or other harmful activities. We diagnose and fix
technology problems, conduct security investigations and risk assessments, and improve and enforce our
security measures. We also use your information to comply with legal and regulatory requirements and
proceedings, including defending legal claims, meeting corporate reporting obligations, and adhering to
applicable laws.
· We may use your personal information to monitor, investigate, prevent, and/or
mitigate violations of our terms of use. We also enforce our agreements with third parties and business
partners, ensuring that all parties abide by the established rules and regulations.
· We may use your information for any other lawful purpose or a purpose that you
have consented to. This provides flexibility in using data in a manner that is both legal and beneficial
to you and our business.
To provide a seamless gaming experience, our application may request the following permissions:
· INTERNET (android.permission.INTERNET)
This permission allows the application to access the internet to communicate with servers and
retrieve game data.
· ACCESS_NETWORK_STATE (android.permission.ACCESS_NETWORK_STATE)
This permission enables the application to check the network connection status, determining
whether the device is connected to Wi-Fi or mobile data. This helps optimize network usage and enhance the
user experience.
· ACCESS_WIFI_STATE (android.permission.ACCESS_WIFI_STATE)
This permission allows the application to obtain detailed information about the Wi-Fi connection,
such as the current connection status and signal strength. This helps improve the quality of online
gaming.
· VIBRATE (android.permission.VIBRATE)
This permission allows the device to vibrate during gameplay, enhancing the gaming experience by
providing haptic feedback to simulate in-game interactions.
· POST_NOTIFICATIONS (android.permission.POST_NOTIFICATIONS)
This permission allows the application to send push notifications to users. These notifications
aim to prompt users to return to the game, stay informed about in-game events, and enhance overall
engagement.
We ensure that all requested permissions are transparently disclosed to users through the following
methods:
· Privacy Policy: This Privacy Policy explicitly lists all permissions required
by the application and describes their purposes in detail.
· App Installation Prompt: During the installation of the app, users will receive
system-generated prompts explaining why each permission is necessary. Users can choose to accept or deny
permissions.
· In-App Settings: Users can view or manage granted permissions at any time by
accessing the app's settings or device settings. This ensures full control over data access.
· Notification Preferences: For permissions such as POST_NOTIFICATIONS, users
will be provided with an opt-in or opt-out option during app installation or via in-app notifications
settings.
· Usage Explanation: For permissions like VIBRATE and ACCESS_WIFI_STATE, we
provide tooltips or additional context in the game's settings or tutorials to explain how these
permissions enhance the gameplay experience.
We respect user choices and do not collect or use permissions beyond the stated purposes. Users
can withdraw permissions at any time without compromising core functionalities, except for those necessary
for the application to operate (such as INTERNET access for online play).
· Transfer to Third Parties for Service Provision: We may transfer personal information
to third parties with the aim of providing the Services. We may disclose personal information to our
appropriate affiliates, including third-party service providers, to ensure the seamless delivery of the
Services to you. These third-party service providers are strictly prohibited from retaining, sharing,
storing, or using the personal information for any other purpose than the specific services they are
contracted to provide.
Sharing in Specific Cases
· Legal Requirement: In cases where the law mandates it, we will share the
necessary information. This is to ensure compliance with legal obligations and to cooperate with
regulatory authorities.
· Business Changes: If the team undergoes mergers, acquisitions, changes in
control, etc. of other companies, information may be shared as part of the business transition process.
This is to ensure the continuity and integrity of our services.
· Selected Third-Party Companies: We may share your information with certain
third-party companies, such as advertising platforms. However, we impose strict requirements on these
third parties. They must (i) ensure the security of the data, (ii) never use the data for purposes other
than providing services to us, and (iii) use the data only in accordance with this Privacy Policy.
· Consent Requirement: In any situation other than those mentioned above, we will
not share your personally identifiable information with third parties without obtaining your prior
consent. This gives you control over the dissemination of your personal information.
Advertise
If you do not wish for us to use the information we collect to serve you advertisements, you have
the option to opt out of receiving such advertisements. Please note the following:
· Operational Data Collection: Even if you choose to opt out, we may still
collect some data about your online activities for operational purposes, such as fraud prevention.
However, this data will not be used for advertising to you.
· Multi-Browser/Device Consideration: If you use multiple
browsers or devices, you may need to perform the opt-out process on each one. This is to ensure that your
preferences are consistently applied across all your access points.
· Third-Party Variability: Other advertising companies' opt-out features may
differ from ours, and we have no control over the practices of any third parties. We make no
representations or warranties regarding such opt-out services. These services are independent of us, and
we have no control over, and are not responsible for, their performance.
We place an extremely high value on the safeguarding of our intellectual property rights. The meticulous
selection and artful arrangement of all the content, be it images, designs, graphics, text, logos,
buttons, interfaces, icons, audio and video clips, as well as our software and services, are the exclusive
possessions of our company. These are all shielded by the Berne Convention, international copyright laws,
and other pertinent legal statutes.
You are required to use our Software and Services only for legal and legitimate purposes. We
reserve the prerogative, without incurring any liability towards you, to terminate or suspend your access
to all or any part of the Software and Services without prior notice in the event that we have reason to
believe that your actions violate any applicable laws or this Privacy Policy, or if such actions are
detrimental to the interests of other users, third parties, sponsors, licensors, service providers,
merchants, and so on.
It is our policy not to solicit any confidential or proprietary information from you, regardless
of the means of communication, be it email or otherwise. Any information, materials, suggestions, ideas,
or comments that you choose to send to us will be regarded as non-confidential. By voluntarily submitting
such information to us, you bestow upon us the unrestricted right to utilize, modify, reproduce, transmit,
display, and distribute it without any obligation to provide payment or other forms of compensation to
you. However, we will refrain from using your name unless it is legally necessary to identify the origin
of the material, information, advice, ideas, or opinions, or unless we have obtained your prior consent.
We respect the privacy of children. Our Services are not intended for or directed towards children or minors under the age of 18. We kindly request that you do not use the Services if you are under 18. We are committed to complying with applicable laws and regulations regarding minors, including the United States' Children's Online Privacy Protection Act. Specifically, we do not knowingly solicit or collect personal information from individuals under 18. If we discover that any personal information has been inadvertently collected from a child, we will take immediate steps to delete the information.
CALIFORNIA PRIVACY
These additional California Privacy Disclosures (the "CA Disclosures") supplement the information
in our Privacy Policy and are applicable only to individual residents of the State of California
("consumers" or "you"). These CA Disclosures provide further details on how we collect, use, disclose, and
otherwise process the personal information of California residents, both online and offline, within the
scope of the California Consumer Privacy Act of 2018 ("CCPA"). Unless otherwise explicitly stated, all
terms in these CA Disclosures have the same meaning as defined in our Privacy Policy or as otherwise
defined in the CCPA. For the purposes of these CA Disclosures, "personal information" has the meaning
provided by the CPA and does not include publicly available information, deidentified or aggregated data
that cannot be associated with us, or information excluded from the CCPA's scope. This section does not
apply to information related to our employees, contractors, and other personnel.
As a California resident, you may be entitled to exercise the following rights (subject to certain
legal limitations):
Right to Know: You have the right to know any or all of the following information
regarding your personal information that we have collected and disclosed in the last 12 months, upon
verification of your identity:
· The specific pieces of personal information we have collected about you.
· The categories of personal information we have collected about you.
· The sources of the personal information.
· The categories of personal information that we have disclosed to third parties
for a business purpose, and the recipients of such information.
· The categories of personal information we have sold and the third parties to
whom the information was sold.
· The business or commercial purposes for collecting or selling the personal
information.
Right to Request Deletion: You have the right to request the deletion of personal
information we have collected from you, subject to certain exceptions (please note that if you choose to
delete certain personal information, we may be unable to provide you with access to our services, and we
will inform you if this is the case).
Right to Opt Out of Personal Information Sales: You have the right to opt out of
the sale of your personal information to third parties now or in the future.
EUROPEAN PRIVACY
These European Privacy Disclosures supplement the information in our Privacy Policy and apply to
our processing of your personal information if you are based in the EEA. For the purposes of EEA data
protection laws, we are the controller of the personal information we receive from you as described in
this Privacy Policy. This means we are responsible for and control the processing of this personal
information. The following tables provide further details on the categories of personal information we
collect about you, how we use it, the legal basis for processing, and the recipients of the data. We will
indicate to you where the provision of certain personal information is necessary for us to offer you
specific features of our Services. If you choose not to provide such personal information, we may not be
able to provide those parts of our Services to you or respond to your other requests.
Right to Withdraw Consent: You have the right to withdraw consent at any time
when we are relying on it to process your personal information. However, this will not affect the
lawfulness of any processing that occurred before you withdrew your consent. If you withdraw your consent,
we may not be able to provide the Services to you, and we will inform you if this is the case.
Right to Access: You have the right to request access to your personal
information (commonly known as a "data subject access request"). This enables you to receive a copy of the
personal information we hold about you and to check that we are processing it lawfully.
Right to Correction: You have the right to request the correction of any
incomplete or inaccurate personal information we hold about you. We may need to verify the accuracy of the
new information you provide.
Right to Erasure: You have the right to request the deletion or removal of your
personal information where there is no valid reason for us to continue processing it. You also have the
right to ask for deletion or removal if you have successfully exercised your right to object to processing
(see below), if we have processed your information unlawfully, or if we are required to erase it to comply
with local law. Please note that we may not always be able to comply with your request for erasure due to
specific legal reasons, and we will notify you if applicable.
Right to Object: You have the right to object to the processing of your personal
information when we are relying on a legitimate interest (or that of a third party) and you have a valid
reason based on your particular situation. You also have the right to object to processing for direct
marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to
process your information that override your rights and freedoms.
Right to Restriction of Processing: You have the right to request the restriction
of the processing of your personal information in the following scenarios:
· If you want us to establish the accuracy of the personal information.
· If our use of the personal information is unlawful but you do not want us to
erase it.
· If you need us to hold the personal information even if we no longer require it
for you to establish, exercise, or defend legal claims.
· If you have objected to our use of your personal information and we need to
verify whether we have overriding legitimate grounds to use it.
Right to Transfer: You have the right to request the transfer of your personal
information to you or to a third party. We will provide your personal information in a structured,
commonly used, machine-readable format. Please note that this right only applies to automated information
that you initially consented to our use or that we used to perform a contract with you.
If you have questions or comments about this Policy, please contact us through the in-game support system or by emailing [email protected].
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