N3TWORK Privacy Policy

Last Updated: August 4th, 2020

This Privacy Policy explains how N3twork Inc. ("N3TWORK", "we" or "us") collects, uses, and discloses information we receive from your (“you” or “users” ) use of our software, games, mobile applications, products, websites (including domains owned, operated or controlled by N3TWORK), and services, (“Products”) and from third parties. This Privacy Policy does not apply to any third-party websites, products, services, or applications, even if they are accessible through our Products.

Before you use any of our Products or submit any information to us, please carefully review this Privacy Policy. If you have any concerns about providing data to us or having it used in any manner permitted in this Privacy Policy, you should not use our Products.

We may revise our Privacy Policy at any time and in our sole discretion. The most current version of our Privacy Policy will govern our use of your information and will be posted on our website and within our apps. If any revision, in our sole discretion, is material, we will send you a notification or post a notice on our website or in our mobile apps.

By continuing to use our Products after any revisions become effective, you agree to be bound by the revised Privacy Policy.

Information We Collect

The types of personal information we may collect and our privacy practices depend on the nature of the relationship you have with N3TWORK, which N3TWORK Products (or features within a Product) you use, and the requirements of applicable law. Generally, and unless otherwise called out in this Privacy Policy, “personal information” is information that relates to an identified natural person or could be reasonably linked so as to identify a natural person. We endeavor to collect information only relevant to our legitimate business purposes or for lawful purposes of processing.

For example, we may collect information about you (directly, automatically, or from third-party sources) when you:

  • download and/or use one of our mobile applications or other Products
  • create and/or register a N3TWORK account
  • create a user profile or customize your experience within one of our Products
  • sign-up to receive our company and/or Product announcements or alerts
  • interact with other users, including by posting or sharing your content in forums, message boards, or elsewhere in our Products
  • use any of our Products on or through social media or networking services
  • purchase any of our Products
  • use our referral services to tell a friend about any of our Products
  • use our Products' features to search for a friend (which may include a follower if you are an influencer on social media) or group of friends, to invite a friend, or to communicate with one or more friends
  • contact us, respond to our communications to you, or interact with us through our Products or on social media
  • interact with our advertisements, contests/sweeps, or promotions

Information You Provide Us

When you use our Products, you may directly provide us:

  • your account name
  • your name and/or alias
  • your picture
  • your contact information including phone number, email address and mailing address
  • your interactions with other users
  • voice and audio information when you choose to use audio features
  • payment information (For clarity, we do not collect credit card or bank account numbers. Instead, payments are processed by the mobile application store you use to download our games and make in app purchases. We may, however, collect limited payment information around prize fulfillment, such as the email address associated with your PayPal account)
  • questions and/or feedback you provide to us within our Products, including in comments in community boards or through customer service
  • location, such as precise location and country ID from which you are playing

Additionally, some of our Products (or Product features) may require that you provide us (directly or through our service providers) further information for compliance purposes, such as to verify your eligibility and/or identity as a pre-condition of your use of the Product or Product feature, including:

  • your age
  • identification documents and other information as may be required to verify you in accordance with applicable laws and regulations or for fraud verification in connection with any large prize fulfilments
  • permanent and temporary address
  • tax-related information
  • location, such as the country ID from which you are playing

Information Automatically Collected through use of our Products

Through your use of our Products, we may receive the following information about you:

  • your user ID number and account name
  • the in game user ID numbers of your friends
  • your interactions with other users
  • your gameplay, use history, content, and purchases
  • technical information about your computing device, such as your IP address, device ID, device type, and/or microphone or speakers (when you choose to use audio features)
  • operating system
  • browser, domain and other systems information
  • usage statistics about your interaction with our Products, including Products used, referring, landing and exit pages, pages used or visited, number of clicks, domain names, browser language, clickstream data, amount of time spent on particular pages, your game play, and your interaction with other users of our Products

When you use our mobile applications, we also may collect mobile device information like operating system and hardware type, telemetry, diagnostic, and sensory data, numbers or codes that are unique to your particular device (such as IDFA or an Android Ad ID), device information, default device language, the location of your device (at a GPS level), microphone or speakers (when you choose to use audio features), and app usage information. This data also may be linked to your other information, including your location data.

Information We May Collect from Third Parties

If you play our games or access any of our other Products on connected third party applications or connect our Products to any third party applications, including social networks, we may receive certain information about you from the provider of the third party application. The information we receive depends on the N3TWORK game you’re playing, the third party application, your privacy settings and, if applicable, your friends’ privacy settings on that third party application. If you access our Products from a third-party application or connect our Products to a third-party application, you should also read that third-party application’s terms of service and privacy policy. If you are unclear about what information a third party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

N3TWORK may collect information about you from third-party sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided us and to enhance our ability to provide you with information about our business, products, and services. N3TWORK’s agreements with these third-party sources typically limit how we may use this supplemental information.

How We Use Your Information

We acquire, hold, use and process personal information you provide for a variety of business purposes including to:

  • create your accounts in our Products
  • provide you with our Products
  • verify your identity and account in Products
  • identify that you have logged in to our Products
  • generally manage your information and account(s)
  • help us better understand how you interact with our Products, personalize and improve your experience with our Products, and develop, provide, customize and improve our Products and processes
  • evaluate the effectiveness and popularity of our Products
  • detect and prevent fraud
  • fulfill prizes
  • learn about your playing habits and show you more relevant advertising
  • enforce the legal terms that govern your use of the Products
  • respond to your comments, concerns, questions, and requests
  • comply with our legal obligations, resolve any disputes we may have with you or others, and to enforce our agreements with third parties
  • send you announcements, newsletters and promotional materials related to our Products and, in N3TWORK’s discretion, changes to any N3TWORK policy
  • enable you to communicate with other users
  • offer you opportunities to participate in surveys, contests or sweepstakes
  • keep you posted regarding our latest product announcements and those of our partners, software updates and upcoming promotions, contests and events
  • market to you and/or
  • for any other purposes disclosed at the time you provide personal information or otherwise with your consent

Anonymous and Aggregated Information

Anonymized or aggregated information is not personal information. N3TWORK may use such information in a number of ways, including, without limitation, measuring users’ interests and use of the Products or features within any one of the Products, internal analysis, analytics, and research. We may also share this information with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

Push Notifications

We may request to send push notifications to your mobile device to provide Product updates and other relevant messages. You can manage push notifications from the “options” or “settings” page within the mobile application or through your mobile device’s settings page for the mobile application.

How We Share Your Information

We may share or disclose your information as further detailed below.

Sharing with Your Consent

We may share or disclose your information with your consent or at your direction. This includes sharing or disclosing your information that you post or share through our Products, information in your interaction with friends and other players of our games and information with other services such as social or other media or networking services when you have chosen to allow our Products to interact with those services.

Sharing Location Data

Unless you explicitly opt-in to permit the use and sharing of your personal information regarding the geographic location of your computing device, your location data will only be collected and used anonymously in a form that does not personally identify you. Please note that some location-based services may require your personal information for the feature to work as intended.

Sharing with Our Service Providers

We may engage third-party service providers to work with us to perform certain services in connection with our providing the Products to you, including hosting services, customer service, marketing services, data analysis, payment processing and order fulfillment, and to help us understand, develop, provide and improve the Products that we offer. These third-party service providers may have access to your personal information based on our instructions only for the purpose of performing services on our behalf, and are subject to security and confidentiality obligations limiting the use and disclosure of your personal information

We do not directly collect payment information as payments will be processed through the mobile application store you use. We may collect limited information from you when we award prizes (e.g., an email address associated with your PayPal account). In such instances, that email will be used and stored for the purposes of fulfilling the prize and for compliance reasons.

Sharing with Our Partners

In connection with the development and provision of our Products and the provision of games of our partners, we may partner with third-party developers, publishers and/or licensors, and other business partners to assist us in providing you with our Products or products of our partners for which you provided your information to us. We only share such information with our partners pursuant to an agreement by which our partner is under obligations not to disclose or use such information for any other purpose. If you wish to no longer have your personal information used by our partners, you may contact us at privacy@n3twork.com and we will facilitate your request to the partner. By electing to not share your information with one of our partners, you understand that your ability to use or access, in whole or part, our Products or the products of our partners may be limited.

Sharing with Third Parties

We may share or disclose your non-private, de-identified, aggregated, or otherwise non-personal information with third parties, including third-party publishers, advertisers and ad networks, and businesses with which we partner.

Sharing with our Related Entities and Affiliates

We may share information with our affiliated companies that are under common control or ownership with N3twork, Inc.

Disclosure in Connection with Business Transactions

We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, N3TWORK will endeavor to direct the transferee to use personal information in a manner that is consistent with this Privacy Policy.

Disclosure in Connection with Legal Requests or Litigation

We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; and (iii) under the discovery process in litigation.

Disclosure to Protect our Interests or Prevent Illegal Activity and Harm

We may disclose information about you: (i) to enforce N3TWORK policies or contracts or protect the rights or property of N3TWORK or applicable third parties; (ii) to collect amounts owed to N3TWORK; (iii) when we believe disclosure is necessary to prevent financial loss; (iv) to detect, prevent, or stop activity we consider to be illegal, fraudulent, or unethical or to address security or technical issues, or (v) when we have a good faith belief that disclosure is otherwise necessary or advisable, e.g., if there is an imminent threat to the health or safety (physical or otherwise) of you, another person, or the public generally.

Social Media, Profile, Messaging, or Chat Sharing

We urge you to exercise care and caution when providing information about yourself (e.g., in your in-game character name, user profile, communications to other users of our Products in forums, message boards or elsewhere in our Products) that may be publicly viewable through our Products to others. We recommend that you not publicly disclose any personal information. For example, we recommend that you not use your real name or other information that may be used to personally identify you or contact you as part of your in-game character name, through our messaging or chat Products, or your public posts. N3TWORK is not responsible for the activities of other users, our partners or other third parties with whom you choose to provide your personal information or otherwise interact and/or the manner in which such information is used by others.

Tracking Technologies, Online Behavioral Advertising, and Do Not Track Signals

As further described in our Cookie and Opt-Out Policy, we, service providers acting on our behalf, such as Google Analytics, and third party developers, publishers, and/or our third-party advertisers use “cookies”, pixels, web beacons, log data and similar tracking technologies when you use our Products or Product features or if you engage with advertisements (ours or those of a third party) and our email communications. For example, we, and our third party service providers, partners, developers, and/or publishers may utilize these technologies to provide the Products, better understand how you interact with our Products, improve our Products, customize and personalize your experience, personalize our advertisements to you (within our own Products and on third party sites) and track advertisements effectiveness, and for security purposes. Third party advertising partners, developers, and publishers may use these technologies may also place their own cookies on your browser. Where third-party service providers, advertisers, such as companies delivering advertisements in our Products, developers and publishers may also use cookies or other technologies, and the practices of such third parties are subject to their own privacy policies and you should visit the websites of third-party providers to obtain further information on how they use cookies. Learn more about your choices and ways to opt out in our Cookie and Opt-Out Policy.Please note, however, that if you do not accept cookies, you may not be able to access all portions or features of our Products.

“Do Not Track”

When using N3TWORK’s online services, N3TWORK may collect personal information about individual users’ online activities over time and across different web sites or online services operated by N3TWORK. To use N3TWORK’s online services, individual users are connected to their specific accounts and, therefore, N3TWORK does not respond to Do Not Track (“DNT”) signals. N3TWORK shares advertising identifiers with third-party advertising partners and may allow third-party advertising partners displaying advertisements on N3TWORK’s websites and other online platforms to collect personal information about individual users’ online activities over time and across different web sites or online services.

International Users

Residents of the European Economic Area (“EEA”) and some other jurisdictions outside the United States have certain legal rights with respect to the personal data we hold about them. Such residents may request that we:

  • provide access to personal data we hold about them (including, in some cases, in portable form)
  • rectify such data
  • delete certain personal data
  • object to our uses or disclosures of personal data or exercise legal rights to withdraw consent

Such requests will be processed in line with local laws, including without undue delay and in accordance with any required time frames. Although N3TWORK makes good faith efforts to provide individuals with access to their personal information, there may be circumstances in which N3TWORK is unable to provide access, including, but not limited to,: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If N3TWORK determines that access should be restricted in any particular instance, we will endeavor to provide you with an explanation of why that determination has been made within any required time frames (approximately one month), a contact point for any further inquiries and any other legally required information. To protect your privacy, N3TWORK will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.

To exercise any of the above rights (or any other rights under applicable law), please email us at privacy@n3twork.com.

In addition to the rights above, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concerns.

Legal Bases for Use of Your Information

The legal bases for using your information as set out in this Privacy Policy are as follows:

  • as necessary to provide you with Products or perform our obligations under a contract with you
  • to fulfill our legitimate interests or the legitimate interests of others (for example, to provide security for our Products; operate our business and our Products; make and receive payments; comply with legal and regulatory obligations; defend our legal rights; prevent fraud; and to know the customer to whom we are providing Products); and
  • on the basis of implied or express consent, such as to send you certain information, including certain marketing communications.

N3twork Inc. is the controller of personal data collected under this Privacy Policy (unless we indicate otherwise).

International Transfer of Personal Information

All personal information sent or collected by N3TWORK may be stored anywhere in the world, including but not limited to, in the United States, on the cloud, our servers, the servers of our affiliates or the servers of our service providers. By providing information to N3TWORK, you consent to the storage of your personal information in these locations, which may have privacy protections less stringent than your jurisdiction.

As set out in this Privacy Policy, N3TWORK may share personal information with our service providers, consultants and affiliates to provide you with a product or service that you have requested or for our and our affiliates’ internal business purposes. If you are located outside the United States and choose to provide your personal information to us, we may transfer your personal information to the United States and process it there, and you consent to such transfer and processing in the United States.

The Security of Your Information

We take reasonable administrative, physical and electronic measures to protect your personal information. Unfortunately, however, no security system can be 100% secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. Accordingly, we cannot guarantee the absolute security of any information

Links to Other Sites

Our Products may contain links to other websites, and may provide access to products, services and applications owned or provided by third parties not affiliated with or controlled by N3TWORK. Any information that you provide on or to a third-party website, product, service or application is provided directly to the owner of that website, product, service or application and is subject to that party’s privacy policy. We recommend that you carefully review the privacy policies of the websites, products, services and applications that you access. You agree that N3TWORK is not responsible for, nor will N3TWORK be liable to you or any third-party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information you choose to provide to them.

Marketing Communications

You may instruct us not to use your information to contact you by email, postal mail, or phone regarding Products, services, promotions and special events that might appeal to your interests by following the instructions located at the top or bottom of such emails or by emailing us at privacy@n3twork.com. Removing your name from the email list may take a reasonable amount of time. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

Retention

N3TWORK will retain personal information for as long as you use our Products or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or based upon such other criteria required to comply with contracts and applicable laws.

California Consumers Privacy Rights

The California Consumer Privacy Act (“CCPA”) and other California privacy laws provide California residents specific rights in connection with our collection, use, storage, disclosure and processing of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

Collection, Use, and Disclosure

The "Information We Collect" section describes that categories of data we may collect from you, which include, for example, account and registration information, name and contact information, alias, demographic and statistical information, financial and transactional information, personal identifiers, customer service information, communications with other users, research, survey, or sweepstakes information, information about others, browser and device information and identifiers, connection and usage data, geolocation information, sensory information (such as telemetry and video recordings of gameplay), voice and audio information when you use audio features, and questions, comments, or other information you post or share directly with us or within our Products.

The "Information We Collect" and "Tracking Technologies, Online Behavioral Advertising, and Do Not Track Signals" sections explains the sources from which we collect information about you, including, for example, you, service providers, other users, third party applications, analytics providers, cookies and tracking technologies, survey partners, related entities and affiliates, developer partners, your interaction with us in our social media channels, and marketing partners.

The "How We Use Your Information" section explains how and why we use your information. You can also see the "Legal Bases for Use of Your Information" section for further information on why we collect your information. Generally speaking, we use your information to provide you with the products and services, communicate with you, personalize your experience, secure our services and users, detect and prevent fraud, defend our legal rights, and comply with the law.

The section on “How We Share Your Information” explains how and with whom we share or disclose your information. We may share all categories of personal information with our related entities and affiliates, service providers, third parties for legal purposes (such as to comply with legal process, enforce our contracts and rights, respond to claims, and protect the rights, property, and safety of N3TWORK, our users, and the public), third parties in connection with a corporate transaction, and others with your consent. We may share contact and account registration information, demographic and statistical information, browser and device information and identifiers, connection and usage data, and personal identifiers with product and marketing partners. We may share user-generated content, communications with others, information about others, and information intended to be public (like a public profile) with other users or the public.

Please also see our "Social Media, Profile, Messaging, and Chat Sharing" and "Tracking Technologies, Online Behavioral Advertising, and Do Not Track Signals" for information on our use of tracking technologies and opt-out choices.

Your Rights and Choices

CCPA Rights Disclosure

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

  • inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting or selling that personal information; and the categories of third parties with whom we share that personal information
  • provide access to and/or a copy of certain personal information we hold about you
  • delete certain personal information we collected from you
  • provide you with information about the financial incentives that we offer to you, if any

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the services to you. We also will take reasonable steps to verify your identity before responding to a request. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please:

California residents may opt out of the “sale” of their personal information. We do not “sell” California residents’ personal information under the CCPA, based on our current understanding of the definition of “sell”. We do share certain information as set forth in “How We Share Your Information” and allow third parties to collect certain information about your activity, for example through cookies, as explained in the “Social Media, Profile, Messaging, and Chat Sharing” and “Tracking Technologies, Online Behavioral Advertising, and Do Not Track Signals” sections. However, we provide further information on your right to opt out of certain collection and use practices to help you better understand your choices which you can find in our “Cookie and Opt-Out Policy” page.

Other California Disclosures

The California Civil Code permits customers of our Products who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident and have provided N3TWORK with personal information within the last year, you may make such a request by contacting us at privacy@n3twork.com.

If you are under 18 and resident in California, you may request and obtain removal of content or information posted by you on our Products as a registered user of our Products. You may request removal by contacting us at privacy@n3twork.com with (i) the email address or user name associated with your registration and (ii) a description sufficient to identify and locate each item of content and/or information posted on our Products by you as a registered user of our Products that you wish removed. Please note that as permitted or required by applicable law, removal does not ensure complete or comprehensive removal of the content or information posted on our Products by you as a registered user. Within 30 calendar days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for such third parties’ direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. A request may be made no more than once per calendar year and we are not required to respond to requests made by means other than through the email address above.

Nevada Users Privacy Rights

Nevada law provides its residents to opt out of the current and future “sale” of their “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” under Nevada law includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

We do not currently engage in such activity. Nevertheless, if you are a Nevada resident who has purchased or leased goods or services from us you may submit a request by emailing us at privacy@n3twork.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. If you move out of Nevada after opting out and updating your location, your request to opt out may be voided.

Our Policy Toward Children

Generally, our Products are not intended for or directed to children under the age of 13, or 16 with respect to European Union data subjects (unless an European Economic Area (EEA) member state shall otherwise specify), and we do not knowingly collect personal information from children under the age of 13 in the US or 16 in the EEA. Some of our Products may have stricter age limits, in our discretion, even where we are not required by applicable law to limit to such an age. Children under 13 (or the age of consent in the applicable jurisdiction or the age we require for a specific Product), are prohibited from and should not use or attempt to use our Products or send us any information about themselves. If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@n3twork.com to request that such information be removed from our records. If we learn that we have collected personal information of a child under 13 (or 16 with respect to EU citizens, unless an EEA member state shall otherwise specify), we will take reasonable measures to delete such information from our records.

Questions?

Please contact us at privacy@n3twork.com if you have any questions or comments about our Privacy Policy.

N3TWORK Inc.
PO Box 26209
San Francisco, CA 94126