Privacy Policy
Last Updated:
[2020/09/23]
Welcome to Land of Empires (the“Game”). The Game is provided, operated
and controlled by Nuverse (Hong Kong) Limited, whose registered address is at Suite 1113A, 11/F., Ocean
Centre, Harbour City, 5 Canton Rd, Tsim Sha Tsui, Kowloon, Hong Kong. (“Nuverse”, “we” or
“us”).
This policy explains how we collect, use and disclose your personal data when you access
the Game and the rights you may have under applicable privacy laws. If you do not agree with this policy, you
should not play the Game.
If you have any questions about how we use your personal data, please contact
landofempires2019@gmail.com
Below is a summary of key points in our Privacy Policy.
This privacy policy consists of a main body and a jurisdiction-specific section. The
jurisdiction-specific section might include additional information required under local data protection laws
and/or render certain aspects of the body policy to be inapplicable or amend them accordingly due to local data
protection laws.
SUMMARY
What data do we collect about you?
We collect and process your data when you create an account and play the Game, including
your contact details, location data and other data you provide when you register for an account, create or share
content via the Game,or play the Game. We also collect data you share with us from third parties (such as
Facebook, Kakao or Google) if you choose to log in to the Game via your account with such third party networks,
and technical and behavioral data about your use of the Game. We may also collect data about you automatically
through your use of the Game.
How and for what purpose will we use the data about you?
We use your data to provide the Game to you and to improve and administer it. We may also
use your data to, among other things, improve and develop the Game and ensure your safety. We may also use your
personal data to serve you targeted advertising and promote the Game and other products and services (in each
case, if required under applicable law, where we have your consent).
Whom do we share your data with?
We share your data with affiliated and unaffiliated service providers who help us to
deliver the Game including advertising analytics providers, customer service provider (including AIhelp that
provides chatbox and live chat, and will collect data directly from the users) and technical support providers who
enhance game operations, improve the Game experience conduct debugging, and provide general support services.
Where required or permitted by law, we will share your data with law enforcement agencies or regulators and with
third parties pursuant to a legally binding court order.
Your Rights
In certain circumstances, you have rights in relation to your data such as the right to
access and the right to correction. Depending on your jurisdiction, you may have additional rights - please see
the jurisdiction - specific provision at the end of this Privacy Policy.
How long do we keep hold of your data?
We retain your data for as long as it is necessary to provide you with the Game service
so that we can fulfill our contractual obligations and rights in relation to the data involved. Where we do not
need your data in order to provide the Game to you, we retain it only as long as we have a legitimate business
purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain
your data if necessary for the establishment, exercise or defense of legal claims.
How will we notify you of any changes to this Privacy Policy?
We will generally notify all users of any material changes to this policy through a notice within the Game when you log in. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.
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1.The types of personal data we use
Unless otherwise stated in this policy, the personal data we collect from you or about
you is required so that we can perform our contract with you to provide the Game to you as detailed in our Terms
of Service. The provision of certain data is mandatory for the purposes of your access to the Game, and if you do
not provide your age data required by us for account set up purposes, we will not be able to grant you access to
the Game. If you do not provide certain types of data, such as your location data, we may not be able to provide
certain aspects of the Game service or certain functionalities may be lost. However, you have control over certain
kinds of personal data that you can choose to share or to withhold from us, and still be able to access the Game,
as detailed in this policy.
We collect and use the following data about you:
Data You Provide to Us, Including Your Profile Data. You give us data
when you register an account to play the Game via the application directly or if you choose to register using your
social network account details (e.g. Facebook, Kakao and Google), including your name, gender, age, language,
and/or email address, data you disclose in your user profile, your photograph or profile photo as well as photos
and videos you choose to upload from your device while using the Game, for which you grant us access to your
camera and or your device's photo album, character name or nickname, age data to verify an account, in a limited
manner and data you voluntarily elect to provide in order to customize game play, such as gender. If you choose to
find other users through your social network account contacts, we will access and collect them and match that data
against existing users of the Game. We link your data with your activity on our Game across all your devices,
using your email or other log-in or device data.
We also collect data in correspondence you send to us.
Behavioral and Use Data.
Gameplay
We process data regarding your use of the Game including login history, purchase history,
how you engage with the Game, the preferences you set such as choice of language, the amount of time spent in the
Game, your game play and activity including e.g. your loot box records, item flow, coin flow, battle records,
tutorial participation, transfer in-game resources, game session duration, and your high scores, your Game
progress, your interactions with other players inside the Game, "share"records, download records and other pieces
of data in connection with your various activities within or through the Game or otherwise that are sent by your
browser, device or computer system when you access the Game, which are automatically tracked and recorded by our
servers. We also link your subscriber data with your activity on our Game across all your devices using your
email, phone number, or similar data that you have provided.
Your participation in tournaments or other online gaming events is conditional upon you granting Nuverse permission to collect, use, store, transmit and publicly display statistical data, such as your scores, rankings and achievements, generated through your participation.
Surveys
We collect data through surveys, challenges and competitions in which you may participate
including gender, likeness, age and preferences.We also infer your preferences, including your interests, gender
and age for the purpose of serving personalized advertising (with your consent, if required under applicable law).
We will also process your personal data in order to tell you about services and
opportunities.
Messages
We collect and process, which includes scanning and analyzing, data you provide in the
context of composing, sending, or receiving direct messages to and from other players, either directly on our
websites and apps or to third party social media account and whether by words, audio, video or photos and your
communications with us e.g.in the context of customer support including audio messages. That data includes the
content of the message and data about when the message has been sent, received and/or read, as well as the
participants of the communication.
Message Boards and Chat Rooms
We may also collect additional data you share about yourself such as on the Game’s
message boards, chat rooms and in the Game, including comments, images, photos, links, stickers and emojis. Any
actions you perform with other players are considered public and are solely at your discretion, and therefore you
should have no expectation of privacy or confidentiality. You may choose to disclose data about yourself in the
course of contributing user generated content to the Game or in its chat rooms, blogs,message boards, user
“profiles” for public view, or in similar forums on its sites through mobile services and/or through third party
sites or services. You should be aware that any personally identifiable data you submit in the course of these
public activities can be read, collected, or used by other users of these forums, and could be used to send you
unsolicited messages.
Feedback
We also collect data and content of messages you provide to us through your feedback such
as product reviews you write, or questions and data you provide for customer support. In this case, we may collect
and store your contact data that you give them (i.e. your name and email address), your social network or service
user ID number. When you contact us, such as for customer support, phone conversations or chat sessions with our
representatives may be monitored and recorded.
Data from Third Parties. You may choose to share certain data with us
from third parties or through your use of the Game. We have set out further details on the data we receive from
third parties below:
Social Networks
If you choose to register to use the Game using your social network account details (e.g.
Facebook, Kakao and Google), you will provide us or allow your social network to provide us with your username and
public profile (including your name, profile picture, gender, networks, user IDs, list of friends, followers and
accounts you follow, date of birth, email address, and any other data you have set to public on your account). We
may also access posts in your news feeds, friend data or fan pages and any other data included in your social
network or online profile including blacklists, "likes" given and received, even if you are not using the social
network. Please note that if you allow Nuverse to have access to this data, then Nuverse will have access
to data even if you have chosen not to make that data public.
Advertising Service
Providers
We use the data collected from you, and your interaction with the Game to infer your
likely interests to provide you with more relevant advertising, if you provide your consent for us to do so (where
required by applicable law). This data tells us about purchases you have made so that we can predict what else
might interest you in the future and assess how effective the advertising on our Game is. We collect this data by
the use of Cookies and similar technologies in our Game and from similar data received from third parties who
advertise through our Game and whose sites you visit.
Technical Data we collect about you. We automatically collect certain
data from you when you use the Game. Such data includes your IP address, time zone settings, browser type,
language, data regarding the device or hardware you are using to access the Game such as the model of your device,
mobile device’s unique identifier (UDID) or serial number, cellular information, WiFi network, identifier for
vendor (IDFV), source of user (where you use your account on a third party platform to log in), device screen
resolution, mobile carrier, software, platform, incident data, network type, device ID, operating system, a list
of installed packages and running apps or processes, file names and types, Android ID, Google Advertising ID and other third-party apps, other third-party apps you have on your device, as well as other types of data sent by
your browser or device when you access the Game, domain names, landing pages, pages viewed and the order of those
pages, amount of time spent on particular pages, referring pages, exit pages and URLs, number of clicks, and the
date and time of this activity which are automatically tracked and recorded by our servers. Where you log-in from
multiple devices, we will be able to use your profile data to identify your activity across
devices.
Location. We use the ‘Region’ you select in Settings to customize your
Game experience. When you play the Game on a mobile device,we will collect data about your location, including
your country, zip code, area code and geolocation. In certain jurisdictions, with your permission, we will collect
Global Positioning System (GPS) data and mobile device location data based on your SIM card. If you do not wish to
share your precise location with us, you can switch off location services via the settings on your mobile
device.
Find other users and invite your friends. you can choose whether to find
other users of the Game among your contacts in your preferred social networks who have a Game account. The Game
supports and often encourages you to interact with other players. If you choose to find other users through your
social network contacts, we will collect your public profile data as well as names and profiles of your social
contacts. If you play through a social network or register through asocial network, your social network friends
will see your name, profile photo and descriptions of your Game activity. Similarly, other players, regardless of
whether they are your social network friends or not, will be able to see descriptions of your Game activity and
view your Game profile, which may include your name or a “game name” and your profile photo. Other players may
also be able to send you Game requests or even friend requests. You can also use this function to invite your
contacts to join you in playing the Game. We will use the contact data you have for that person, from Facebook
friends (or other similar social network) list and give you the option to send them either an SMS, email or third
party message (such as Facebook (including Facebook Messenger) or Google) inviting them to play the
Game.
Buy virtual items. If you buy virtual items and advantages via in-app
purchases, we collect your transaction record including how much you spent in the game and items purchased OR your
purchase will be made via your Apple iTunes or Google Play account. When you play the Game or access any of our
other services on connected third-party applications or platforms (like Facebook, Google, etc), any purchases you
make will be processed by that third-party application and subject to that third-party application’s terms of
service and privacy policy. We do not collect any financial or billing data from you in relation to such a
transaction but may receive non-financial data related to your purchase, like your name and approximate physical
location, the fact that you have an Apple Pay or Google Pay account, and the items purchased. Please review the
relevant app store's terms and notices in respect of the handling of such data. So that we can credit your account
with the correct value in virtual items, we keep a record of the virtual assets/items you own, purchases you make,
the time at which you make those purchases and the amount spent.
Other. Nuverse may also receive either non-personal or public data
from third parties in connection with market and demographic studies and/or data that Nuverse may use to
supplement personal data provided directly by you. Nuverse may ask some third-party service providers to
supplement the personal data that you provide to Nuverse for its own marketing and demographic studies, so
that Nuverse can consistently improve its services and related advertising to better meet its visitors' needs
and preferences. To enrich its understanding of individual customers, Nuverse may tie this data to the data
you provide to it.
2.Cookies
We, our vendors and service providers use cookies and other similar technologies (e.g.
pixels, web beacons etc.) (collectively, “Cookies”) to enhance your experience using the Game. We
will obtain your consent to the use of Cookies where required under applicable law.
The types of Cookies and similar technologies used by us and our partners in connection
with the Game can be classified into one of five categories, namely 'essential Game Cookies', 'functionality
Cookies', 'analytics and performance Cookies', 'advertising Cookies', and ' social media Cookies'. Cookies do a
lot of different tasks to ensure you enjoy your use of the Game, for example, they are used to remember your
preferences on sites you visit, to help you navigate between pages more efficiently and to make sure the adverts
you see on our Game are relevant to you and your interests. We have set out some further information about each
category, and the purposes of the Cookies we and third parties set in the following table.
Cookies that are necessary for essential
purposes
These Cookies are essential to provide you with the Game and to use some of its features,
such as to enable you to log. Without these Cookies, we would not be able to provide you with a secure log in
account. We use Cookies to uniquely identify you. Each time you log in to the Game, a Cookie containing a unique
identifier that is tied to your account is placed on your browser. These Cookies allow us to uniquely identify you
when you are logged into the Game and to process your online transactions and requests.
Functionality Cookies
Functionality Cookies record information you have entered or choices you have made. These
Cookies also enable you to optimize your use of the Game after logging in so that we can personalize our content
for you, greet you by name and remember your preference. These Cookies can also be used to remember settings you
have applied, such as layout and text size. These Cookies mean that when you continue to use or come back to the
Game, we can enable you to start the Game from where you left off.
Analytics and Performance
Cookies
We use performance/analytics Cookies to analyze how you use the Game,including your level
in the Game, which tutorials you view, measure any errors that occur and test different design ideas. The
information is used to report and evaluate your activities and patterns as a user of the Game to provide services
in accordance with these activities. These Cookies do not collect information that individually identifies you and
all information these Cookies collect is aggregated and anonymous. We also use third-party analytics tools to help
us measure traffic and usage trends for the Services (with your consent if required under applicable law).
Advertising Cookies
Analytics: As you use the Game, you will notice that it features advertising. We allow
third party companies, including advertising companies, to place Cookies in the Game to track the performance of
our advertisements (with your consent if required under applicable law). As an example, these Cookies remember
which users have used the Game. The information provided to third parties does not include personal information
but it may be associated with personal information after we receive it.
Marketing: We may also (with your permission, where required under applicable law)
contract with third-party advertising networks that collect IP addresses and other information from the Game, from
third party websites and apps. Ad networks follow your online activities and collect information through automated
means (such as through the use of Cookies, again, with your consent, if required under applicable law). Ad
networks use this information, mainly to serve adverts about products and services that are likely to interest
you. We may also partner with third parties to provide certain features in the Game. For advertising purposes, we
may collect your Google Ad ID, Android Ad ID or (where applicable) your IDFA (IDFA stake the place of Cookies in
mobile advertising delivered to iOS devices).
Social Media Cookies
Third parties whose applications are connected to the Game by you will set their own Cookies in order to customize their applications for you. Because of how Cookies work, we cannot access these Cookies, nor can the third parties access the data in Cookies used by us. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via Cookies.
3.How and for what purpose we use your personal data
We may use the data we collect about you in the following ways:
• In accordance with, and to perform our contract with you, we may use your data to:
￮ allow you to play the Game;
￮ notify you about changes to the Game and send Game-related communications to you including via push notifications;
￮ provide you with user support;
￮ enforce and notify you of changes to our terms of service, conditions and policies;
￮ administer the Game including troubleshooting;
￮ enable you to interact with other users;
￮ enable our messaging service to function if you choose to use this function;
￮ enable you to participate in the virtual items program;
￮ administer loyalty programs and tailor its offerings, web pages or game play experience to you;
￮ administer sweep stake, contests, or similar promotions where you enter into such programs;
￮ communicate relevant information (such as updates and security alerts) and provide support to you; and
￮ verify and confirm payments.
• In order to comply with our legal obligations, we may use your data to help us detect
abuse, fraud and illegal activity in the Game;
• In accordance with our legitimate interests to provide an enjoyable and safe Game experience, we may use your data to:
￮ ensure your safety and security including reviewing messages and associated metadata for breach of our terms of service and other inappropriate content;
￮ ensure the Game is presented in the most effective manner for you and your device;
￮ improve, promote, update and develop the Game and your experience;
￮ better understand customer behavior and improve our products and services through analytics;
￮ carry out data analysis and test the Game to ensure its stability and security and data about installed packages and running apps or processes in order to ensure the security of the Game network and prevent the spread of viruses and malware;
￮ allow you to participate in social and interactive features with others in the Game;
￮ to enable you to socialize in the Game environment, for example, by allowing other users to identify you via the “Find other friends” function or through their phone contacts, and will allow your contacts to associate your account (and relating gaming entitlements, including games played and other data (with you);
￮ to ensure that you are old enough to play the Game (as required by law);
￮ provide you with advertising and promotional emails (with your consent, if this is required by law), namely by sending messages regarding new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest; and
￮ to provide you with location-based services (where those services are available in your jurisdiction and you choose to share your precise location with us, and with your consent, if this is required by law).
4.How we share your personal data
We share your data with the following selected third parties:
Social Networks
If you choose to register to use the Game using your social network account details (e.g.
Facebook, and Google), you will provide us or allow your social network to provide us with your user name and
public profile (including your name, profile picture, gender, networks, user IDs, list of friends, date of birth,
email address, and any other data you have set to public on your account).
If you access third-party services, such as Facebook, or Google, to login to the Game or
to share data about your usage of the Game with others, these third-party services may be able to collect data
about you, including data about your activity on the Game, and they may notify your connections on the third-party
services about your use of the Game, in accordance with their privacy policies.
To manage the data Nuverse receives about you from a third-party application, such as
Facebook, you will need to follow the instructions for the third-party application for updating your data and
changing your privacy settings. To review and update data associated with the game profile in certain games, visit
the “settings” page in that game. You can also manage some aspects of data collection and use by visiting the
“settings” page of your mobile device and reviewing the permissions of each application or “app.” Once Nuverse
receives your data from a third-party application or your mobile device, that data is stored and used by
Nuverse in accordance with this Privacy Policy. You may access and update that data as described
herein.
Payment Providers
If you choose to buy virtual items,we will share data with the relevant payment provider
to facilitate this transaction. We share a transaction ID to enable us to identify you and credit your account
with the correct value in virtual items once you have made the payment.
Advertising Service
Providers
We share data with advertisers and third party measurement companies to show how many and
which users of the Game have viewed or clicked on an advertisement. We will also share non-personal and personal
data e.g. IDFA, IP address, time zone settings, browser type, language, operating system, network connection type
and speed, and data regarding the device or hardware you are using to access the Game such as the model and make
of your device, you may refer to the advertisers' privacy policy for more information.
Please note, after clicking on a third party advertisement, you may no longer be on a
site hosted by Nuverse or the social network through which you are playing the Game. If you no longer want to
receive tailored in-Game advertisements from third parties, you may adjust your privacy settings.
For more data about how our analytics providers collect data from the Game, please see
the above section on Cookies.
Service Providers
We provide data and content to service providers who support our business, including but
not limited to cloud service and data storage providers, maintenance service providers, customer service providers
(including AIhelp that provides chatbox and live chat, and will collect data directly from the users) and
technical support providers who enhance game operations, improve the Game experience, conduct debugging, analytics
and provide general support services. We contractually require these third party service providers to maintain the
confidentiality of the data we share with them, and we require them not use your data for anything other than to
provide services on our behalf.
Our Corporate Group
We may also share your data with other members, subsidiaries, or affiliates of our
corporate group, to provide the Game including improving and optimizing the Game, preventing illegal use and
supporting users.
Law Enforcement
We may share your data with law enforcement agencies, public authorities or other
organizations if legally required or permitted to do so,or based on our legitimate business interests if such use
is reasonably necessary to:
• comply with a legal obligation, process or request Nuverse is not required to question or contest the validity of any legal process, search warrant, subpoena or other similar governmental request that it may receive;
• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect and defend the rights, property or safety of us, our users, a third party or
the public as required or permitted by law including exchanging data with other companies and organizations for
the purposes of fraud protection and credit risk reduction.
Social Features of the Game
If you choose to engage in the social features of the Game e.g. sending messages to
others, you should be aware that any data you share may be read, collected, or used by other users. You should use
caution in disclosing personal data while engaging. We are not responsible for the data you choose to share with
other players.
Sale or Merger
We will also disclose your data to third parties:
• in the event that we sell or buy any business or assets (whether a result of Liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
• if we sell, buy, merge, are acquired by, or partner with other companies or businesses,
or sell some or all of our assets. In such transactions, user data may be among the transferred
assets.
5.International data transfers
The personal data that we collect from you may be transferred to, and stored at, or
otherwise processed in a destination outside of your jurisdiction of residence. Please see the
jurisdiction-specific terms at the end of this privacy policy for further information relevant to your
jurisdiction.
6.Your Rights
You may have the following rights under applicable laws:
• The right to request free of charge (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained;
• The right to request proper rectification or removal of your personal data or restriction of the processing of your personal data; and
• The right to object to processing your personal data for the purposes of sending you
promotional messages.
Before we can respond to a request to exercise one or more of the rights listed above,
you may be required to verify your identity or your account details.
Depending on your jurisdiction, you may have additional rights. Please see the
jurisdiction-specific provisions at the end of this Privacy Policy.
Please send an e-mail to [insert email] if you would like to exercise any of your rights.
We will respond to your request consistent with applicable law and subject to proper
verification.
In addition:
• You may be able to refuse or disable Cookies by adjusting your browser settings.
Because each browser is different, please consult the instructions provided by your browser. Please note that you
may need to take additional steps to refuse or disable certain types of Cookies. In addition, your opt-out
selection is specific to the particular browser or device that you are using when you opt out, so you may need to
opt-out separately for each browser or device. If you choose to refuse, disable, or delete Cookies, some of the
functionality of the Game may no longer be available to you.
• You may opt out of receiving advertising and/or marketing communications by following the instructions in such communications or by using options provided in the game settings.
• You can switch off GPS location data functionality on your mobile device if you do not wish to share GPS data.
• Some browsers transmit “do-not-track" signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
• If you have registered for an account you may access, review, and update certain personal data that you have provided to us by logging into your account and using available features and functionalities.
• If you want to remove your contacts stored by us, follow the instructions provided in
the game to request that we remove them from our systems. If you need to enter a password to allow us to access
your address book, we will not store that password.
7.The security of your personal data
We take steps to ensure that your data is treated securely and in accordance with this
policy. Unfortunately, the transmission of data via the internet is not completely secure. Although we will do our
best to protect your personal data, for example, by encryption, we cannot guarantee the security of your data
transmitted via the Game; any transmission is at your own risk.
We will, from time to time, include links to and from the websites of our partner
networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these
websites have their own privacy policies and that we do not accept any responsibility or liability for these
policies. Because Nuverse cannot control the activities of third parties, it cannot accept responsibility for
any use of your personal data by such third parties, and it cannot guarantee that they will adhere to the same
privacy and security practices as Nuverse. Please check these policies before you submit any data to these
websites.
8.How long do we keep your personal data
We retain your data for as long as it is necessary to provide you with the service so
that we can fulfill our contractual obligations and rights in relation to the data involved. However, there are
occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is
necessary for the establishment, exercise or defense of legal claims.
9.Data relating to children
The Game is not directed at children under the age of 13 and we do not knowingly collect
or solicit personal data from children under 13. If you believe that we have personal data about or collected from
a child under the relevant age, please contact us at landofempires2019@gmail.com and we will ensure that it is
deleted.
10.Complaints
In the event that you wish to make a complaint about how we process your personal data,
please contact us in the first instance at landofempires2019@gmail.com and we will endeavor to deal with your
request as soon as possible. This is without prejudice to your right to launch a claim with the relevant data
protection authority.
11.Changes
We will generally notify all users of any material changes to this policy,through a
notice provided via the Game and providing any other notice required by applicable law. However, you should look
at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this
policy, which reflects the effective date of such policy. Your continued access to or use of the Game after the
date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated
policy, you must stop accessing or using the Game.
12.Translations
In the event of any conflict or inconsistency between the terms in the English and any translation thereof in any other language,the English version shall prevail.
13.Contact
Questions, comments and requests regarding this policy should be addressed to landofempires2019@gmail.com.
Supplemental Terms – Jurisdiction-Specific
In the event of a conflict between the provisions of the Supplemental Terms
–Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the Services, and the
rest of policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and
control.
EUROPEAN JURISDICTIONS
Germany
In the Summary, under How will we notify you of any changes to this Privacy Policy?,
the following sentence shall be deleted:
By accessing the Game, you acknowledge that you have read this policy and that you
understand your rights in relation to your personal data and how we will collect, use and process
it.
Section 11 (Changes) is modified to delete the sentence:
Your continued access to or use of the Game after the date of the updated policy
constitutes your acceptance of the updated policy.
EEA and Switzerland
In Section 2 (Cookies), the following shall be added:
We will only make use of Cookies to obtain and share your data if you provide your
express consent. You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness of
the processing based on consent before its withdrawal.
In Section 3 (How we use your data), the following shall be added:
• With your consent, we will use your data (including ad identifiers, age, region, gender, language, data related to your use of the Game and interactions with others, messages including content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication, username and public profile) to:
￮ conduct surveys as outlined in the body section of this privacy policy including telling you about services and opportunities;
￮ collect and process, which includes scanning and analyzing, data you provide in the context of composing, sending, or receiving messages through the Game messaging functionality. That data includes the content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication;
￮ monitor and record customer support communication, phone conversations or chat sessions with our representatives;
￮ access posts to your social media walls, posts in your news feed and access your social network data at any time, including any of your favorite websites, friend data or fan pages and any other data included in your application, social network or online profile, even if you are not using the social network or you chose not to make that data public;
￮ collect and process certain technical data, namely list of installed packages and running apps or processes and third-party apps you have on your device;
￮ collect data about your location. In certain jurisdictions, with your permission, we will collect Global Positioning System (GPS) data and mobile device location data based on your SIM card;
￮ find other users and invite your friends in your preferred social networks as outlined in the body section of this privacy policy and to show descriptions of your game activity and game profile to other players on the social network, regardless of whether they are your social network friends or not;
￮ supplement personal data provided directly by you with either non-personal or public data from third parties in connection with market and demographic studies and/or data that Nuverse may use, or to ask third-party service providers to supplement the personal data that you provide to Nuverse for its own marketing and demographic studies, and to tie individual customer data to data you provide to Nuverse.
￮ to send you direct marketing via email or SMS; and
￮ use cookies as outlined under section 2.
You may withdraw your consent at any time and such withdrawal shall not affect the
lawfulness of the processing based on consent before its withdrawal.
The following shall be added to section 5 - International data
transfers:
The personal data that we collect from you will be transferred to, and stored at, a
destination outside of the European Economic Area (“EEA”).
Where we transfer your personal data to countries outside the EEA, we do so under the Commission’s model contracts for the transfer of personal data to third countries
(i.e. standard contractual clauses) pursuant to 2004/915/EC or 2010/87/EU (as
appropriate). For a copy of these Standard Contractual Clauses, please contact us at
landofempires2019@gmail.com.
The following shall amend section 6 - Your Rights:
• Right to request access to your personal data: You have the right to obtain from us
confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to
request access to the personal data. The access information includes - inter alia - the purposes of the
processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the
personal data have been or will be disclosed. However, this is not an absolute right and the interests of other
individuals may restrict your right of access.
You have the right to obtain a copy of the personal data undergoing processing free of
charge. For further copies requested by you, we may charge a reasonable fee based on administrative
costs.
• Right to request rectification: You have the right to obtain from us the rectification
of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to
have incomplete personal data completed,including by means of providing a supplementary
statement.
• Right to request erasure (right to be forgotten): You have the right to obtain from us
the erasure of personal data concerning you and we may be obliged to erase such personal
data.
• Right to request restriction of processing: You have the right to obtain from us that
we restrict the processing of your personal data. In this case, the respective data will be marked and may only be
processed by us for certain purposes.
• Right to data portability: Where processing of your personal data is either based on
your consent or necessary for the performance of a contract with you and processing is carried out by automated
means, you have the right to receive the personal data concerning you in a structured, commonly used and
machine-readable format or to have your personal data transmitted directly to another company, where technically
feasible;
• Right to withdraw consent: Where the processing of your personal data is based on your
consent,you have the right to withdraw your consent at any time without impact to data processing activities that
have taken place before such withdrawal;
• Automatic decision making: You have the right not to be subject to any automatic
individual decisions, including profiling, which produces legal effects on you or similarly significantly affects
you unless we have your consent, this is authorized by EU or EU Member State law or this is necessary for the
performance of a contract;
• Right to Object: You have the right to object to processing if we are processing your
personal data on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds
which may override your right. If you object to such processing, we ask you to state the grounds of your objection
in order for us to examine the processing of your personal data and to balance our legitimate interest in
processing and your objection to this processing; and
• Right to complaint: You have the right to lodge complaints before the competent data
protection authority.
These rights might be limited under applicable national data protection law.
Please send an e-mail to landofempires2019@gmail.comif you would like to exercise any
of your rights. We will respond to your request consistent with applicable law and subject to proper
verification.
Section 8 (How long we keep your personal data) is modified to
add:
Where we do not need your data in order to provide the service to you,we retain it only
for so long as we have a legitimate business purpose or other valid legal basis for keeping such
data.
Section 9 (Information relating to children) shall be replaced with the
following:
The Game is not directed at children under the age of 16 and we do not knowingly collect or solicit personal data from children under 16. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at [insert email] and we will ensure that it is deleted.
ASIA-PACIFIC JURISDICTIONS
Australia
The following definition shall apply to the Privacy Policy:
"Personal data" means "personal information" as defined in the
Privacy Act 1988 (Cth), i.e., information or an opinion, whether true or not, and whether recorded in a
material form or not, about an identified individual, or an individual who is reasonably
identifiable.
The following shall be added to Section 5 - International data
transfers:
The personal data that we collect from you will be transferred to, and stored at, a
destination outside of Australia, in particular in Singapore and the United States of
America.
The following shall replace Section 12 - Contact:
If you have any questions about the Privacy Policy, or would like to complain about a
breach of the Australian Privacy Principles, or are concerned about the handling of your personal data, please
contact the privacy officer at landofempires2019@gmail.com. Please contact the privacy officer on the
details provided in this Privacy Policy if you wish to access your personal data and/or seek correction of your
personal data. If you are not satisfied with the response or do not receive a response within a reasonable time
frame, you may have the right to take your complaint to the Office of the Australian Information Commissioner
(OAIC). Current contact details for the OAIC are available on the OAIC's website at
www.oaic.gov.au.
Hong Kong
Section 3 (How we use your personal data) is modified to add:
We intend to use your personal data (name and email address) for promotional marketing
purposes, namely to send you messages concerning new products, features, enhancements, special offers, upgrade
opportunities,contests and events of interest in relation to the Game. We require your express consent (for use)
and written consent (for transfer) before we do so.
We will not transfer your personal data to other parties for gain.
Japan
The following shall be added to Section 5 - International data
transfers:
The personal data that we collect from you will be transferred to, and stored at, a
destination outside of Japan, in particular in Singapore and the United States of America.
South Korea
Section 3 (How we use your personal data) is modified as follows:
We intend to use your personal data (name and email address) to send you promotional
messages concerning new products, features, enhancements, special offers, upgrade opportunities, contests and
events of interest in relation to the Game. We require your express consent before we do
so.
Section 4 (How we share your personal data) shall be modified as follows:
We share your data with the following selected third parties:
Service Providers
We provide data and content to service providers who support our business, such as cloud
service and data storage providers, and technical support providers who enhance game operations, improve the Game
experience, conduct debugging, and provide general support services. Details of the service providers are as
follows:
| enable users to log in via Google account and to use Google Play purchase | ||
| Apple | enable users to log in via Apple ID account and use Apple iTunes purchase | |
| enable users to log in via Facebook account | ||
Section 8 (How long we keep your personal data) shall be replaced with the
following:
In principle, we will promptly destroy your personal data in our possession once we
achieve the purpose of collection and use of your personal data.
Procedure and Method for Destruction of Personal
Data
In principle, we will promptly destroy your personal data in our possession once we
achieve the purpose of collection and use of your personal data.
Your personal data will be destroyed after storage for a certain period pursuant to our
internal policy or applicable laws and regulations (please refer to the provisions on retention and use period).
Personal data stored in electronic file format will be deleted by using technical means that will not allow data
recovery.
Section 9 (Data relating to children) shall be replaced with the
following:
The Game is not directed at children under the age of 14 and we do not knowingly collect
or solicit personal data from children under 14. If you believe that we have personal data about or collected from
a child under the relevant age, please contact us at landofempires2019@gmail.com and we will ensure that it is
deleted.
For children under the age of 14, their legal guardians have the right to exercise the
rights of their children with respect to data protection.
Taiwan
Section 5 (International data transfers) shall be modified as
follows:
The personal data that we collect from you may be transferred to, and stored at, or
otherwise processed in destination outside of your jurisdiction of residence, including Singapore and the United
States.
The following wording shall be added to Section 6 - Your rights:
• "The right to request the cessation of the collection, processing or use of your
personal data."
Malaysia
The following sentence shall be added in the second paragraph of the Privacy Policy
before "If you do not agree with this policy, you should not play the Game":
"By accessing the Game or providing us with your personal information, you consent to
your personal data being collected, stored, used, processed and disclosed asset out in this policy, including the
transfer of your personal data outside of Malaysia."
The following shall be added to Section 5 (International data
transfers):
"You hereby expressly consent that the personal data that we collect from you may be
transferred to, and stored at, a destination outside of Malaysia. For the places where the personal data is
transmitted, retained or processed outside of Malaysia, we will take reasonable measures to protect that personal
data."
The first paragraph of Section 6 (Your rights) before "Before we can respond to
a request to exercise one or more of the rights listed above, you may be required to verify your identity or your
account details" shall be deleted in its entirety and replaced with the following:
"You may have the following rights under applicable laws:
• The right to request free of charge (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained;
• The right to request proper rectification or removal of your personal data or restriction of the processing of your personal data, including personal data relating to other persons who may be identified from that personal data; and
• The right to object to processing your personal data for the purposes of sending you
promotional messages."
Section 12 (Contact) shall be deleted in its entirety and replaced with the
following:
"Questions,comments and requests regarding this policy should be addressed to
landofempires2019@gmail.com."
Vietnam
Section 3 (How we use your personal data) is modified to add:
“We intend to use your personal data for promotional marketing purposes, including to
send you promotional messages concerning new products, features, enhancements, special offers, upgrade
opportunities, contests and events of interest in relation to the Game. We require your express consent to do
so.”
Section 4 (How we share your personal data), the first sentence is modified to
read:"You expressly consent that we may share your data with the following selected third
parties:"
Section 5 (International data transfers), the first sentence is modified to
read: "You expressly consent that the personal data we collect from you may be transferred to, and stored at, or
otherwise processed in a destination outside of your jurisdiction or residence."
Section 6 (Your Rights), the following shall be added:
Section 9 (Data relating to children) shall be replaced with the following:
The Game is not directed at children under the age of 16 and we do not knowingly collect
or solicit personal data from children under 16. If you are reviewing these terms as the parent/legal guardian of
a user who is under the age of 16, you hereby declare that such user is above the age of 13 and that you have read
and acknowledged Nuverse Privacy Policy and Terms of Use and agree to the use by your child of the game and
registration for an account. Further, if you believe that we have personal data about or collected from a child
under the relevant age, please contact us at landofempires2019@gmail.com and we will ensure that it is
deleted.”.
THE AMERICAS
Canada
The following shall be added to Section 5 - International data
transfers:
The personal data that we collect from you will be transferred to, and stored at, a
destination outside of Canada, in particular in Singapore and the United States of America for the purposes stated
under this Privacy Policy. We may disclose your personal data to foreign law enforcement and national security
authorities in such jurisdictions in accordance with this Privacy Policy.
The following shall replace Section 12:
Contact
If you have any questions, comments and requests regarding this policy, or would like to
obtain written information about the organization's policies and practices with respect to service providers
outside of Canada, please contact landofempires2019@gmail.com.
The data protection officer for can be contacted as follows:
landofempires2019@gmail.com.
USA
Data relating to children
Section 9 (Data relating to children) is modified to
add:
Nuverse respects the privacy of parents and children, and is committed to complying
with the Children’s Online Privacy Protection Act (“COPPA”). If a parent believes that his or her
child under the age of 13 has submitted personal data to Nuverse, he or she can contact us via email:
landofempires2019@gmail.com.
MIDDLE EAST JURISDICTIONS
Turkey
Section 2 (Cookies) shall include the following:
“We will only make use of non-essential Cookies to obtain and share your data if you
provide your explicit consent. You may withdraw your consent at any time and such withdrawal shall not affect
the lawfulness of the processing based on consent before its withdrawal.”
Section 3 (How we use your data) shall include the following:
“Based on Article 5(1) of the Turkish Data Protection Law, with your consent, we will use
your data (including ad identifiers, age, region, gender, language, data related to your use of the Game and
interactions with others, messages including content of the message and data about when the message has been sent,
received and/or read, as well as the participants of the communication, username and public profile)
to:
You may withdraw your consent at any time and such withdrawal shall not affect the
lawfulness of the processing based on consent before its withdrawal.
References in this policy to the 'performance of contract' as a legal basis refers to the
legal basis under Article 5(2)(c) of the Turkish Data Protection Law, where the processing of your personal data
is necessary for and directly related to the establishment and/or performance of our contract with
you.
References in this policy to 'our legal obligations' or 'legal requirements' as a legal
basis refers to the legal basis under Article 5(2)(ç) of the Turkish Data Protection Law, where the processing of
your personal data is mandatory for compliance with our legal obligations under applicable laws; and/or Article
5(2)(a) of the Turkish Data Protection Law, where the processing is expressly laid down in
laws.
References in this policy to our 'legitimate interests' or 'legitimate business
purposes'as a legal basis refers to the legal basis under Article 5(2)(f) of the Turkish Data Protection Law,
where the processing of your personal data is mandatory for our legitimate interests, provided that it does not
violate your fundamental rights and freedoms.
References in this policy to 'the establishment, exercise or defense of legal claims'
refers to the legal basis under Article 5(2)(e) of the Turkish Data Protection Law, where the processing of your
personal data is mandatory for the establishment, exercise or defense of a legal claim.”
Section 6 (Your rights) shall be amended as follows:
“You have the following rights with respect to your personal data:
Please send an e-mail to landofempires2019@gmail.com if you would like to exercise any
of your rights. Before we can respond to a request to exercise one or more of the rights listed above,you may be
required to verify your identity or your account details.
We will respond to your request as soon as possible according to the nature of your
request and within thirty days at the latest, free of charge. However, if your request incurs additional cost to
us, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.
”
Section 9 (Data relating to children) shall be replaced with the
following:
“The Game is not directed at children under the age of 18 and we do not knowingly collect
or solicit personal data from children under 18. If you are under the age of 18, please have your parent or legal
guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under
the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged
Nuverse Privacy Policy and Terms of Use and agree to the use by your child of the game and registration for an
account. Further, if you believe that we have personal data about or collected from a child under the relevant
age, please contact us at landofempires2019@gmail.com and we will ensure that it is
deleted.”
Section 11 (Changes) is modified to delete the sentence:
“Your continued access to or use of the Game after the date of the updated policy constitutes your acceptance of the updated policy.”