PRIVACY POLICY

Effective Date:  April 2023

Nitro Games Plc and its affiliates (“Nitro Games”, “us”, “our” or “we”) are dedicated to protecting the privacy rights of our users (“users” or “you”).

This Privacy Policy (the “Policy”) explains the ways we collect, store, use, or otherwise process the information, including personal data, that you provide or we collect in connection with our websites (the “Sites”), any Nitro Games’ game provided on a mobile platform (for example, iOS and Android) or when you otherwise interact with us (collectively, the “Services”) and what rights you have if we are processing your personal data.

We may periodically update this Policy by posting a new version. If we make any material changes, we will notify you as required under applicable law, including by posting a notice in the Services prior to such change becoming effective. Your continued use of the Services after the effective date will be subject to the new policy.

1. INFORMATION WE COLLECT

Data you provide to us

When you access or use our Services, we collect data you provide to us voluntarily. The types of data we may collect about you include your name, email address, player name, data you provide to us in connection with competitions, promotions or other events and any other data you choose to provide.

Data we collect automatically

When you access or use our Services, we automatically collect certain data of you and/or your device. This information we collect either with your explicit consent, to perform the contract with you or based on our legitimate interest to do so (in accordance with GDPR) including:

• Your age (as indicated by you)
• Your game progress and account that is connected to your unique device ID (which is used to save your progress to the cloud)
• Your unique Support ID (to track your use of our Services and to allow our customer support to locate your user account for troubleshooting purposes)
• Your username (generated by you)
• Log information such as your IP address, browser type, pages viewed and visited prior navigating to our Services
• Country (derived from your IP address)
• Device and OS Information (such as device ID, advertising ID, Media Access Control (“MAC”) address or mobile network information)
• Data about your use and/or consumption of our Services
• Data about your interactions with other players within and inside our Services
• Your access and participation in message boards on the Services
• Your participation in surveys regarding the Services
• Your participation in a sweepstakes or contest through the Services
• Other information collected by cookies and other tracking technologies

Data we collect from third parties

We may collect and obtain information from other source such as social media platforms, service providers and advertising networks to supplement the information we have about you.

Cookies

A cookie is a small text file that we transfer to your computer and/or device, to identify a user’s computer/device and to “remember” things about your visit, such as your preferences or a username and password. Information contained in a cookie may be linked to your personal data for purposes such as improving the quality of our Services, tailoring recommendations to your interests, and making the Services easier to use. You can disable cookies at any time, although you may not be able to access or use certain features of the Services.

We may feature advertisements served by third parties that deliver cookies to your computer/device so the content you access and advertisements you see can be tracked.

Ad Networks and other third-party service providers

In order for us to continue offering our Services for free, we may feature advertising within our Services by showing our own, or third-party advertisements, as well as advertise our own Services via third parties. For the purposes of delivering targeted advertising (also known as interest-based advertising) to you, we may disclose your advertising ID to the ad networks. Advertising IDs means the Identifier for Advertisers (“IDFA”) on iOS devices and Google Advertising Identifier (“GAID”) on Android devices and these identifiers are consistent across all apps installed on the device. As advertising IDs are used by ad networks for other purposes as well in addition to the targeted advertising, we encourage you to check their privacy policies to learn more about their data processing practices. You can find a list of Nitro Games existing ad networks partners and other third party service providers by clicking here. You can opt out of interest-based advertising by using the device-level opt out setting on your device. If you use Apple device, the opt-out guide can be found here and for Android devices, navigate to the Google Settings page, select Ads and then choose to reset your Android Ad ID or opt-out of targeted ads.

Our Services may also include social media interaction tools, Application Program Interfaces (APIs) and/or Software Development Kits (SDKs) which allow these partners to access your data including geo-location to provide you with interest-based advertisement, offers and other similar content. You can disable location-based services anytime from the settings of your mobile device.

Our Services may also include analytics services provided by a third-party service provider. These partners may use cookies and other tracking technologies to collect information of your use of our Services. This information may be used by Nitro Games (and others) to analyze and track data, analyze performance of our Services, serve advertisements based on your interest and better understand your activity within our Services.

2. HOW WE USE INFORMATION

We may use your information collected through our Services for purposes described in this Policy or disclosed by you in connection with our Services for various business purposes, including:

• operate and improve our Services;
• develop new Services;
• create game accounts and allow users to play our games and use our Services;
• identify and suggest connections with other Nitro Games users;
• understand you and your preferences to enhance your experience and enjoyment using our Services;
• respond to your comments and questions and provide customer service;
• provide and deliver products and services you request;
• send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
• communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by Nitro Games;
• enable you to communicate with other users;
• link or combine it with other information we get from third parties, to help understand your preferences and provide you with better Services;
• partners who help us to provide the Services (advertising, analytics, hosting) and
• to keep our Services safe and fair.

3. WE MAY DISCLOSE YOUR INFORMATION

We may share your information (which may include personal data) or allow third parties to access the information as described in this Policy or as follows:

• With other users and/or players.
• Third parties providing services to us, for example hosting, analytics or other service providers who help us operate the Services.
• To comply with the law; enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection.
• To our affiliates and in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company.
• With your consent.

We may share aggregated or anonymous information about you that cannot reasonably be used for your identification.

4. SECURITY

Nitro Games takes reasonable measures to protect your information from unauthorized access or against loss, misuse, or alteration. The measures we employ vary, but typically include, for example, encryption of data and use of pseudonymisation, whenever feasible.

5. CHILDREN

Generally, our Services are not intended for children.

We do not knowingly collect or solicit personal data from anyone under the age of 13 (or under 16 in certain jurisdictions) or knowingly allow such persons to use our Services except as described in this section. In the event, we become aware that child has provided us with personal data, we will delete that information as quickly as possible, unless we have a legal obligation keep it.

As some of our games may appeal to children, we have taken additional step to limit access to these Services by verifying the player’s age. Even if you indicate yourself below the age needed, you can continue accessing our Services, however there will be no profiling, targeted advertising, or geolocation tracking.

Information we collect from children in NERF: Superblast

nerfsuperblast.com is open to users of all ages and we offer a restricted mobile version of the NERF: Superblast game for children. Children are provided with a generated username and can update that username using a username generator that includes a pre-determined list of names. Players can add friends and participate in matches. We automatically collect data from children when they play NERF: Superblast and visit NERF website. This information is not shared with any other third parties and we collect it to learn more about your use of the application and to provide you with the best experience.

Data we collect automatically

• Your game progress and account that is connected to your unique device ID (which is used to save your progress to the cloud)
• Your Support ID (to track your use of our Services and allow our customer service to locate your account for trouble shooting purposes)
• Your username (either generated by you using a list of predetermined words, or created automatically)
• Log information, your IP address, browser type, pages viewed and visited prior navigating to our Services
• Your general location (derived from your IP address). This means we can tell what country you are in .
• Device and OS Information (such as device ID, advertising ID, Media Access Control (“MAC”) address or mobile network information)
• Data about your use and/or consumption of our Services
• Data about your interactions with other players within and inside our Services

Service Providers we use in relation to children in NERF: Superblast

The personal data collected is solely to provide the service as outlined and we do not share this personal data with any other third parties. You can find the list of the service providers used in relation to children in NERF Superblast by clicking here.

NERF Superblast Site

The Nerf Superblast website does not use service providers. However, we do use necessary cookies to operate the Site You can find a list of cookies used by clicking here. You can disable cookies in your browser settings however some parts of the Services may not function properly. Kindly note that our service providers may operate under their own privacy policies.

If you are a parent or legal guardian of a child under the age of 13 (or 16 in certain jurisdictions) and you wish to review the personal data collected or have any questions or comments, please contact us at support@nitrogames.com. If you are an EU Citizen, please also see your rights in section 8 Your Rights.

6. INTERNATIONAL DATA TRANSFER

As our Services are global by nature, and we operate globally we may transfer and/or process your data that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that we may use include standard contractual clauses approved by EU Commission and other lawful safeguards.

7. DATA RETENTION

We will retain your data for as long as needed to provide you the Services, your account is active or we have a legitimate reason to do so; to comply with any legal, accounting, or reporting requirements, resolve disputes and to enforce our agreements.

8. YOUR RIGHTS

You are entitled, at any time, to access and be informed about your data under the applicable laws and regulations. You have a right to:

• obtain information on the processing of your personal data
• access your data
• rectification of your data
• the erasure of your data and to be forgotten
• restrict the processing of your data
• data portability (have your personal data transmitted to another data controller)
• object to the processing of their data
• withdraw your consent (when processing is based on consent).

9. CONTACT INFORMATION

If you would like to action your rights, have questions about data protection, or if you have any requests for resolving issues with your personal data, please contact us at:

Name of the Data Controller:
Nitro Games Plc (Business ID 2134819-6)
Juha Vainion katu 2
48100 Kotka
FINLAND

Phone: +358 440822268

email: support@nitrogames.com

10. COMPLAINTS

In case you consider our processing activities of your personal data to be inconsistent with the applicable data protection laws, you may lodge a complaint with the local supervisory authority for data protection.