PRIVACY
POLICY
Naxos
Games Studio has adopted this privacy policy to explain how Naxos Games Studio
collects, stores, and uses the information collected in connection with Naxos
Games Studio products, services and websites including, but not limited to
Naxos Games Studio Games, Naxos Games Studio Games on-line stores.
Should
you have any questions relating to this Privacy Policy, please contact us.
BY
INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE SERVICES, YOU
AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE
PROCESSING, USE AND DISCLOSURE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS
PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT
INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES. Naxos Games Studio
reserves the right to modify this Privacy Policy at reasonable times, so please
review it frequently. Your continued use of Services will signify your
acceptance of the changes to this Privacy Policy.
1.
Non-personal data
For
purposes of this Privacy Policy, non-personal data means information that does
not directly identify you. Additionally, non-personal data means aggregate and
personalized information, which is data Naxos Games Studio collects about the
use of Naxos Games Studio Services, from which any personally identifiable data
has been removed.
Naxos
Games Studio may use tools or third party analytical software to automatically
collect and use certain non-personal data that does not directly enable Naxos
Games Studio to identify you. The types of non-personal data Naxos Games Studio
may collect and use include, but are not limited to: (i) device properties,
including, but not limited to IP address, Media Access Control (“MACâ€)
address and unique device identifier or other persistent or non-persistent
device identifier ("Device ID"); (ii) device software platform and
firmware; (iii) mobile phone carrier; (iv) geographical data such as zip code,
area code and coarse location; (v) game progress, time used playing, score and
achievements; (vi) other non-personal data as reasonably required by Naxos
Games Studio to enhance the Services and other Naxos Games Studio products and
services.
Naxos
Games Studio may use and disclose to Naxos Games Studio partners and
contractors the collected non-personal data for purposes of analysing usage of
the Services, advertisement serving, managing and providing the Services and to
further develop the Services and other Naxos Games Studio services and
products.
You
recognise and agree that the analytics companies utilised by Naxos Games Studio
may combine the information collected with other information they have
independently collected from other services or products relating to your
activities. These companies collect and use information under their own privacy
policies.
Naxos
Games Studio may supplement your personal and non-personal data with data
received from third parties in connection with demographic, advertisement,
market and other analytics surveys or services.
2. Ad
Serving Technology
Naxos
Games Studio reserves the right to use and disclose the collected non-personal
data for purposes of advertisement by Naxos Games Studio or Naxos Games Studio
partners and contractors. Naxos Games Studio may employ third party ad serving
technologies that use certain methods to collect information as a result of ad
serving through Services. Naxos Games Studio or third parties operating the ad
serving technology may use demographic and location information as well as
information logged from your hardware or device to ensure that appropriate
advertising is presented within the Service. Naxos Games Studio or third
parties may collect and use data for this purpose including, but not limited to
IP address (including but not limited to for purposes of determining your
coarse location), Device ID, MAC, software, applications, hardware, browser
information, internet and on-line usage information and in-game information.
The foregoing data may be used and disclosed in accordance with this Privacy
Policy and the privacy policy of the company providing the ad serving
technology.
You
recognise and agree that the advertising companies who deliver ads for Naxos
Games Studio may combine the information collected with other information they
have independently collected from other services or products. These companies
collect and use information under their own privacy policies. These ad serving
technologies are integrated into Services; if you do not want to be subject to
this technology, do not use or access Services. Although Naxos Games Studio
takes commercially reasonable steps to instruct such advertising companies to
comply with the terms and conditions of this Privacy Policy, Naxos Games Studio
does not have access to or control of third party technologies.
3.
Location Data
To
the extent Naxos Games Studio makes location enabled Services available and you
use such Services, Naxos Games Studio may collect and process your location
data to provide location related Services and advertisements. For example, some
add-ons or offers may be available at dedicated locations. Naxos Games Studio
may use various technologies to determine location, such as GPS, Wi-Fi or other
network-based data such as IP address. Your GPS geo-location is not accessed
without your consent. Notwithstanding Naxos Games Studio partners who are
providing location related parts of the Service, Naxos Games Studio will not
share your GPS geo-location with third parties without your consent. To the
extent Naxos Games Studio makes available GPS geo-location to third parties in
accordance with this Privacy Policy, it will be provided anonymously. Please
note that Naxos Games Studio may share your anonymous coarse location with its
partners.
4.
Personal Data
For
purposes of this Privacy Policy, personal data means personally identifiable
information that specifically identifies you as an individual.
Likely
situations when you make personal data available to Naxos Games Studio include,
but are not limited to: (i) registration for Services, contests and special
events; (ii) accessing Services using a third party ID, such as social
networking sites or gaming services; (iii) subscribing to newsletters; (iv)
purchasing a product or services through Naxos Games Studio online stores; (v)
using tell a friend,"email this page," or other similar features;
(vi) requesting technical support; and (vii) otherwise through use of Naxos
Games Studio Services where personal data is required for use and/or
participation.
The
types of personal data may vary depending on the type of activity you are
engaged in. The personal data Naxos Games Studio may collect, process and use
may include, but are not limited to your name, screen/nick name, Naxos Games
Studio Services or third party service ID, e-mail address, phone number, photo
or other image, birth date, sex, address, friend connections, avatar image,
credit card information, shipping information; and location (only if directly
identifiable to you, otherwise Naxos Games Studio treats location as
non-personal data).
If you
choose to use Naxos Games Studio "tell a friend" or a similar service
about Naxos Games Studio Services or order a gift certificate for your friend,
Naxos Games Studio may store your friend's name and contact details that you
provide to Naxos Games Studio.
Naxos
Games Studio may use personal and non-personal data, both individually and
combined together, for purposes of analysing usage of the Services, providing
customer and technical support, managing and providing Services (including
managing advertisement serving), customizing Naxos Games Studio communications
and to further develop the Services and other Naxos Games Studio services and
products. Naxos Games Studio may combine non-personal data with personal data.
Naxos
Games Studio may use your personal data to send messages to you with
informative and/or commercial content about Naxos Games Studio services or
third party products and services Naxos Games Studio thinks may be of interest
to you, such as new features and services, special offers and updated
information.
Please
note that certain features of the Services may be able to connect to your
social networking sites to obtain additional information about you. In such
cases, Naxos Games Studio may be able to collect certain information from your
social networking profile when your social networking site permits it, and when
you consent to allow your social networking site to make that information
available to Naxos Games Studio. This information may include, but is not
limited to, your name, profile picture, gender, user ID, email address, your
country, your language, your time zone, the organizations and links on your
profile page, the names and profile pictures of your social networking site
friends and other information you have included in your social networking site
profile. Naxos Games Studio may associate and/or combine as well as use
information collected by Naxos Games Studio and/or obtained through such social
networking sites in accordance with this Privacy Policy.
5.
Disclosure and Transfer of Personal Data
Personal
data may be disclosed in accordance with applicable legislation and this
Privacy Policy. Additionally, Naxos Games Studio may disclose personal data to
its parent companies and its subsidiaries in accordance with this Privacy
Policy.
Naxos
Games Studio may hire agents and contractors to collect and process personal
data on Naxos Games Studio behalf and in such cases such agents and contractors
will be instructed to comply with our Privacy Policy and to use personal data
only for the purposes for which the third party has been engaged by Naxos Games
Studio. These agents and contractors may not use your personal data for their
own marketing purposes. Naxos Games Studio may use third party service
providers such as credit card processors, e-mail service providers, shipping
agents, data analysers and business intelligence providers. Naxos Games Studio
has the right to share your personal data as necessary for the aforementioned
third parties to provide their services for Naxos Games Studio. Naxos Games
Studio is not liable for the acts and omissions of these third parties, except
as provided by mandatory law.
Naxos
Games Studio may disclose your personal data to third parties as required by
law enforcement or other government officials in connection with an
investigation of fraud, intellectual property infringements, or other activity
that is illegal or may expose you or Naxos Games Studio to legal liability.
Naxos Games Studio may also disclose your personal data to third parties when
Naxos Games Studio has a reason to believe that a disclosure is necessary to
address potential or actual injury or interference with Naxos Games Studio
rights, property, operations, users or others who may be harmed or may suffer
loss or damage, or Naxos Games Studio believes that such disclosure is
necessary to protect Naxos Games Studio rights, combat fraud and/or comply with
a judicial proceeding, court order, or legal process served on Naxos Games
Studio. To the extent permitted by applicable law, Naxos Games Studio will make
reasonable efforts to notify you of such disclosure through Naxos Games Studio
website or in another reasonable manner.
6.
Data Retention and Correctness
Naxos
Games Studio retains the data collected pursuant to this Privacy Policy for the
period necessary to fulfil the purposes outlined in this Privacy Policy unless
a longer retention period is required or permitted by law. Thereafter if the
collected data is no longer needed for purposes specified in this Privacy
Policy, Naxos Games Studio deletes all aforementioned data in its possession
within a reasonable timeframe. Naxos Games Studio does not verify the
correctness of personal data.
Irrespective
of the above, Naxos Games Studio may still retain some of the data to the
extent such retention is necessary to resolve disputes, enforce Naxos Games
Studio user agreements, and comply with technical and legal requirements and
constraints related to the security, integrity and operation of Services.
7.
Cookies, beacons and tracking
The
Services may use cookies and other technologies such as pixel tags, locally
shared objects, clear GIFs and web beacons. Naxos Games Studio treats
information collected by cookies and similar technologies as non-personal data.
Cookies:
A cookie is a small bit of record-keeping information that websites often
store on a user's computer. Naxos Games Studio cookies do not include personal
data and are typically used to quickly identify your device and to remember
you. You can disable cookies or set your browser to alert you when cookies are
being sent to your device; however, disabling cookies may affect your ability
to use the Services.
Web
Beacons and pixel tags: A web beacon or a pixel tag is an electronic image that
allows Naxos Games Studio to count users who have visited certain pages or
viewed certain advertisements. Web beacons, like cookies, do not include
personal data. E-mails and other electronic communications Naxos Games Studio
sends to you may contain pixel tags that enable Naxos Games Studio to track
your usage of the communication, including whether the communication was opened
and/or what links were followed, if any.
8.
Third Party Terms and Conditions
Please
note that your access to and use of the Services may be subject to certain
third party terms and conditions and privacy policies, including but not
limited to application stores, map data providers, mobile software platforms,
on-line gaming platforms, social networking services and payment providers. You
recognise and agree that Naxos Games Studio is not liable for any such third
party terms and conditions and their use of your personal data.
Naxos
Games Studio may in its discretion make available links through advertisements
or otherwise enable you to access third party products or services. Please note
that, while using such products or services, you are using products or services
developed and administered by people or companies not affiliated with or controlled
by Naxos Games Studio. Naxos Games Studio is not responsible for the actions of
those people or companies, the content of their products or services, the use
of information you provide to them, or any products or services they may offer.
The fact that Naxos Games Studio is linking to those products or services does
not constitute our sponsorship of, or affiliation with, those people or
companies.
Naxos
Games Studio may from time to time make available Naxos Games Studio partners
services, such as sweepstakes or polls and such services may require you to
disclose personal data in order to register for and access such services. Such
services will reasonably identify the partners at the point of where you are
required to disclose personal data. If you at that point choose to disclose
your personal data, such personal data may be transferred directly or via Naxos
Games Studio to such third parties and will be subject to the privacy policy
and practices of such third parties. Naxos Games Studio is not responsible for
the privacy practices and policies of such third parties and, therefore, you
should review the privacy practices and policies of such third parties prior
disclosing any personal data in relation to such services.
Please
note that certain Services that Naxos Games Studio may offer, such as
multiplayer gaming, social networking and gaming console services, may use
third party services to provide authentication for the Services with a gaming
console ID, social networking ID or gaming network account. When you register
to join or use the Services from a third-party gaming or social networking
system, certain personally identifiable user and/or membership data may be
transferred automatically to and from Naxos Games Studio and you hereby consent
to the processing, using, combining, disclosing and retaining of such data in
accordance with this Privacy Policy by Naxos Games Studio.
9.
Safeguards
Naxos
Games Studio follows generally accepted industry standards and maintains
reasonable safeguards to attempt to ensure the security, integrity and privacy
of the information in Naxos Games Studio possession. Only those persons with a
need to process your personal data in connection with the fulfilment of their
tasks in accordance with the purposes of this Privacy Policy and for the
purposes of performing technical maintenance, have access to your personal data
in Naxos Games Studio possession. Personal data collected by Naxos Games Studio
is stored in secure operating environments that are not available to the
public. To prevent unauthorised on-line access to personal data, Naxos Games
Studio maintains personal data behind a firewall-protected server. However, no
system can be 100% secure and there is the possibility that despite Naxos Games
Studio reasonable efforts, there could be unauthorised access to your personal
data. By using the Services, you assume this risk.
10.
Other
Please
be aware of the open nature of certain social networking and other open
features of the Services Naxos Games Studio may make available to you. You may
choose to disclose data about yourself in the course of contributing user
generated content to the Services. Any data that you disclose in any of these
forums, blogs, chats or the like is public information, and there is no
expectation of privacy or confidentiality. Naxos Games Studio is not
responsible for any personal data you choose to make public in any of these
forums.
If
you are under 13 years of age or a minor in your country of residence, please
ask your legal guardians permission to use or access the Services. Naxos Games
Studio encourages parents and/or guardians to play an active role in their
children's online experience at all times. Naxos Games Studio does not
knowingly collect any personal information from children under 13 years of age
and if Naxos Games Studio learns that Naxos Games Studio has inadvertently
gathered personal data from children under 13 years of age, Naxos Games Studio
will take reasonable measures to promptly erase such personal data from Naxos
Games Studio records.
Naxos
Games Studio may store and/or transfer your personal data to its affiliates and
partners in and outside of EU/EEA member states and the United States in
accordance with mandatory legislation and this Privacy Policy. Naxos Games
Studio may disclose your personal data to third parties in connection with a
corporate merger, consolidation, restructuring, the sale of substantially all
of Naxos Games Studio stock and/or assets or other corporate change, including,
without limitation, during the course of any due diligence process provided,
however, that this Privacy Policy shall continue to govern such personal data.
11.
Further information
Naxos
Games Studio makes good faith efforts to enable you to review, update or
correct your personal data in Naxos Games Studio possession. In order to do so,
please contact Naxos Games Studio. Naxos Games Studio will need sufficient
information from you to establish your identity and to verify your access
request, and also to assist us in handling your request. Please note that even
if personal data is changed or deleted according to your request, Naxos Games
Studio may still retain some of your personal data to resolve disputes, enforce
Naxos Games Studio user agreement(s), and comply with technical and legal
requirements and constraints related to the security, integrity and operation
of Naxos Games Studio Services.
Naxos
Games Studio regularly reviews its compliance with this Privacy Policy. If
Naxos Games Studio receives a formal written complaint from you, Naxos Games
Studio will attempt to contact you directly to address any of your concerns.
Naxos Games Studio will cooperate with the appropriate governmental
authorities, including data protection authorities, to resolve any complaints
regarding the collection, use, transfer or disclosure of personal data that
cannot be amicably resolved between you and Naxos Games Studio. Any dispute,
controversy or claim arising out of or relating to this Privacy Policy or the
breach, termination or validity thereof shall be finally settled at Naxos Games
Studio's discretion (i) at your domicile's competent courts; or (ii) by
arbitration in accordance with the Rules for Expedited Arbitration of the
Arbitration Institute of the Indian Chamber of Commerce. The arbitration shall
be conducted in India, in the English language. YOU AGREE THAT YOU MAY BRING
CLAIMS AGAINST Naxos Games Studio ONLY IN YOUR INDIVIDUAL CAPACITY AND NOT AS A
PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.
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