Last Updated: _ 2020/9/25 _
Welcome to "Arena of Evolution: Red Tides" (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
What data do we collect about you?
We collect and process your data when you create an account and play the Game, including your location data,and other data you provide when you register for an account, create and share content via the Game, and play the Game. We also collect data you share with us from third parties (such as Facebook,Twitter, Instagram, Google or Apple) 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.
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 promote the Game and other products and services (and if required under applicable law, only where we have your consent or where you have directed us to do so).
Who else will access and collect your personal data and who do we share your data with?
The third party developer of the Game will have access to your data. Your data may also be collected by/shared with other companies in the same group as the Nuverse, payment providers, and advertising service providers. 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.
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.
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 or using 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.
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. If you do not provide certain name and 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, including your age, language, and/or email address, data you disclose in your user profile including your photograph or profile picture, character name and data you voluntarily elect to provide in order to customize game play, such as gender, and data to verify an account, such as a form of identification in a limited manner. If you choose to find other users through your email contacts, we will access and collect the names and email addresses 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.
We process data regarding your use of the Game including login history, purchase history, how you engage with the Game, the preferences you set, the amount of time spent in the Game, your gameplay and activity, your Game progress, your interactions with other players in the Game, and other pieces of data in connection with your various activities within or through the Game or otherwise (including when you capture a screenshot in the Game) that are sent by your 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 address or similar data that you have provided. When you capture a screenshot, we will give you the option to share the screenshot through either an SMS, email, messaging app or social media platform.
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.
We collect data through surveys, challenges and competitions in which you may participate including gender, likeness, age and preferences. We will also process your personal data in order to tell you about services and opportunities.
We collect and process,which includes scanning and analyzing, data you provide in the context of composing, sending, or receiving messages through the in-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. Please be aware that messages sent to other users of our Game will be accessible by those users and that we are not responsible for the manner in which those users use or disclose messages.
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 detail on the data we receive from third parties below:
If you choose to register to use the Game using your social network account details (e.g. Facebook, Twitter, Instagram, Google or Apple), you will provide us or allow your social network to provide us with your username, contact lists on these services and public profile.
Technical Data we collect about you. We automatically collect certain data from you when you use the Game. Such data includes your IP address, mobile carrier, time zone settings, data regarding the device you are using to access the Game such as the model of your device, device ID and other unique device identifiers, and data about your use of the Game (e.g. number of clicks, landing pages, pages viewed and order of those pages, the amount of time spent on particular pages, the date and time of your request, your game play and activity, your game progress, your interactions with other players inside the Game), your screen resolution, operating system, a list of installed packages and running apps or processes, file names and types, as well as other types of data sent by your browser or device when you access the Game, 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. In certain jurisdictions,with your permission, we will collect Global Positioning System (GPS) data and mobile device location data based on your SIM card and IP address. 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. Likewise, we may also collect data (i.e. recording or screenshot of your gameplay) if you choose to give the Game access to your camera, microphone and photo album (we will not access any photos contained within your album)through your phone setting. You can switch off the access via the settings on your mobile device.
Find other users [and invite your friends]. In addition to finding others through your phone contacts, you can choose whether to find other users of the Game among your contacts in your preferred social networks who have a Game account. 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. [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, either from within your telephone's contact list or Facebook friends list and give you the option to send them either an SMS, email or third party message (such as WhatsApp, Facebook (including Facebook Messenger) or Twitter) inviting them to play the Game.]
(a) What is a Cookie?
Cookies are used to collect data, including personal data, from you. Cookies are small files which, when placed on your device, enable the Game to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as "pixel tags" or "clear GIFs," that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar data from your computer or device.
Cookies are stored on your browser by website or apps that you visit. When you return to that website or app (or visit websites or apps that use the same cookies), these platforms recognize the Cookies and your browsing device.
b) Categories of Cookies
Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies can tell us, for example, whether you have visited the Game before or whether you are a new player.
There are different categories of Cookies, including:
- First-party Cookies
First party Cookies are small amounts of text which are served by us directly to your device.
- Third-party Cookies
Third-party Cookies,which are served by a third party on our behalf. We use third party Cookies for functionality, performance, targeting or social media purposes.
Cookies can remain on your computer or mobile device for different periods of time. Some Cookies are 'session cookies', meaning that they exist only while your browser is open and are deleted automatically once you close your browser. Other Cookies are 'permanent cookies', meaning that they survive after your browser is closed. They can be used by the platform to recognize your computer when you open your browser and browse the Internet again.
c) What types of Cookies do we use and how do we use them?
The types of Cookies and similar technologies used by us and our partners in connection with the Game can be classified into one of four categories, namely 'essential Game Cookies', 'functionality Cookies', 'analytics and performance 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 and to help you navigate between pages more efficiently. 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
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).
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 provide you [with the Game from where you left off].
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);
￮ allow you to participate in social and interactive features of the Game;
￮ provide you with personalized 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.Who else will access your personal data and** how we share your data**
Third Party Game Developer
We work with third party game developers, and the third party developer of the Game will have access to your technical data and other data.
If you choose to register to use the Game using your social network account details (e.g. Facebook, Twitter, Instagram, Google), you will provide us or allow your social network to provide us with your username and public profile.
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. 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.
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
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.
Please send an e-mail to email@example.com 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.
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. Please check these policies before you submit any data to these websites. 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.
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 fulfil 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 firstname.lastname@example.org .
and we will ensure that it is deleted.
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 email@example.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.
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.
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.
Questions, comments and requests regarding this policy should be addressed to
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 youaccess or use the Services, and the rest of policy, the relevant jurisdictions' Supplemental Terms –Jurisdiction-Specific will supersede and control.
_ Germany _
By accessing or using 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:
In Section 3 (How we use your data), the following shall be added:
With your consent, we may 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:
collect and process, which includes scanning and analyzing, data you provide in the context of composing, sending, or receiving messages through the in-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;
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;
send you promotional messages via email or SMS;
You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness ofthe 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 firstname.lastname@example.org .
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 andmachine-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 email@example.com 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.
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 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 firstname.lastname@example.org and we will ensure that it is deleted.
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.
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:
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 important 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 and to 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 [email@example.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.
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: [firstname.lastname@example.org].