EFFECTIVE DATE: 09-13-2018
II. INFORMATION COLLECTED
We may collect and process the following data from and about you.
When you engage in certain activities in the website or access the Services (such as by registering for a user account, downloading and installing application(s), playing game(s), purchasing virtual game items, sending and/or posting user content, or sending us feedback), NHN may collect information about you, but only if you voluntarily provide it to us. The collected Personal Information may include, but is not limited to first and last names, postal addresses, zip codes, phone numbers, self-descriptions, email addresses, social media user names, gender identifications, photos, images, likenesses, dates of birth and other identifying information provided to us by users or otherwise made available by users on or through the Services. We may further store your Services passwords along with related security information used for Service user authentication and to facilitate account access (i.e. hints, answers to security questions, etc.)
The Services may also collect data necessary to process payments, including your method of payment and the method’s corresponding identification numbers (i.e. credit card numbers), and any security code or other verification information associated with your method of payment. The Services’ payment processor stores all payment data. It is suggested that you review the privacy policies of the Services’ payment processor and, if you have any questions concerning the separate practices of the payment processor, to contact the payment processor directly.
NHN does not guarantee the accuracy, completeness, suitability, or veracity of any personal information provided by or otherwise made available on or through the Services by you or others. However, all personal information that you provide on, to or through the Services must be true, complete and accurate, and you must notify NHN of any changes to the personal information you have previously provided or with respect to any inaccuracy therein.
We collect details of your use of our Services and the resources that you access. Such usage information includes information about how and when you access or use our Services (such as games accessed, pages visited, purchases and use of virtual game items, the details of your purchases, and your game play). NHN may use aggregated, non-private, or otherwise non-personal information collected as a result of the user’s access, visitation or use of the Services to analyze the Services’ use and traffic. In addition, NHN may use this information to diagnose problems with the Services’ servers, to improve or administer the Services, to display content and advertisements, to facilitate transactions, to track how users are using the Services, and to improve the Services’ marketing and reporting systems. NHN may sell, transfer, use, share or disclose your non-private, aggregated or otherwise non-personal information, such as, but not limited to, the number of users who visit or used the Services or clicked on a given link, and demographic data with business partners and other third-parties on an aggregated and anonymous basis.
We collect general technical data pertaining to you, such as information about the device you use to access our Services, IP address, operating system, browser type, program or system error messages and other system information. Your IP address is usually associated with the location from which you access the Internet.
User Communication with NHN
If you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence and any personal information set forth therein.
Information from Third Party Social Networks or Platforms
You may allow our Services to interact with a third party social network or platform, such as Facebook, which may provide data about you to us. The information we may obtain from your social media provider or platform will depend on the social media account used. However the information obtained will likely include your first and last name, electronic mail address, “friends” or “following” lists, “likes,” “check-ins,” profile pictures, as well as other facts you have chosen to make public about yourself through the given social media provider. Our ability or permission to access this social media account information might be capable of management through your particular social media account. Further these third party social media applications or websites are created and maintained by third parties which are not a part of, or controlled by us. You are encouraged to read the terms of service and privacy policies of these third party social networks or platforms to understand how they treat your data and what data they might share with us.
Information Collected From Publically Available Sources
We may obtain information about you from other sources outside of your use of, access to or visitation of the Services, including through public databases, from our marketing partners, through social media platforms, and from any other third-party where, with or to whom you have made available any information about yourself.
III. USE AND SHARING OF INFORMATION COLLECTED
Use of Information Collected
NHN may use your Personal Information to send you messages about our company or our features, products or services, or promotional material from some of our partners, or to contact you when necessary, unless you have not consented to allow NHN to use your data.
NHN also may use your Personal Information and Non-Personal Information, both individually or combined together, for editorial and feedback purposes, for marketing and promotional purposes, for statistical analysis of users' behavior, for product development, for content improvement, for customer support and technical support, to manage and provide the Services, and to customize content and layout of the Services.
Names, postal and e-mail addresses and phone numbers collected may be added to our databases and used for future calls and mailings regarding site updates, new products and services, and upcoming events.
Sharing of Information Collected
NHN does not sell or rent your Personal Information to third-parties for marketing purposes without your consent. However, you hereby agree that NHN may, without seeking your further consent, share your Personal Information with affiliate companies of NHN to provide you Services or information about Services or other promotional materials. In addition, NHN may share Personal Information with business partners that assist NHN in providing you Services. NHN is committed to giving you a choice when your Personal Information may be used or disclosed for marketing purposes.
We will encourage our service partners to adopt and post privacy policies. However, the use of your personally identifiable information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.
NHN Service Providers: NHN engages service providers to perform functions and provide basic services (such as hosting, data, customer service, technical support, marketing assistance, mailing assistance, storage security, delivery of services and reporting services) related to the operation of the Services. NHN may share your information with such service providers or their agents who perform services for use on our behalf and require access to such information to do the work for which they have been engaged.
Interactions with Third Party Social Networks or Platforms: You understand that where you allow your account with us to interact with any third party social network or platform, we may share data about you with your contacts (and vice versa) in order that you may enjoy playing socially. This data includes your name, your social media profile, picture and your scores and/or progress in our games.
Compliance with Legal Obligations: Occasionally we may be required by law enforcement or judicial authorities to provide Personal Information to the appropriate governmental authorities. We will disclose Personal Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation.
IV. COLLECTION AND USE OF CHILDREN'S PERSONAL INFORMATION
Our Services are not intended for children under the age of 13, and we do not knowingly collect any personal information from such children. Children under the age of 13 should not use or attempt to use our Services, and if you are under 13, please do not attempt to use our Services or send any information about yourself to us.
Further, in the event that NHN receives personal information that NHN discovers was provided by a child under the age of 13, NHN will promptly delete such personal information in a secure manner. Parents, who believe that we might have any information from or about a child under 13, may submit a request following this link: submit a request that the information be removed.
NHN maintains appropriate safeguards that ensure the security, integrity, and privacy of the personal information we collect and store about our account holders. Personal information collected by NHN is stored in secure operating environments that are not available to the public and that are only accessible by authorized employees. In addition, our online store uses industry-standard encryption to prevent unauthorized electronic access to sensitive financial information such as your credit card number. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control (i.e., maintain data quality). Before we allow web users to access their personal information, for example, we verify their identity by requesting that they submit information such as their username and unique game ID number. We also take reasonable steps to ensure that third parties to whom we transfer personal information provide sufficient protection of such data.
Your personal information may be transferred to, and stored at, a destination outside USA. It may also be processed by personnel of our affiliates and third party service provider who may operate outside USA. In such case, we will take reasonable steps to require such third party in possession of your personal information to take commercially reasonable security measures to protect the information.
However, unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personally identifiable information, you acknowledge that: (a) the security, integrity and privacy of any and all information and data exchanged between you and us through our Services cannot be guaranteed; and (b) any such information and data may be viewed or tampered with in transit by a third party. In the case of such a breach, NHN will make efforts to alert affected users immediately.
VI. LINKS TO THIRD PARTY SITES OR SERVICES
VII. ACCESS TO PERSONAL INFORMATION
VIII. CALIFORNIA RESIDENTS
The “Shine The Light” law, appearing at California Civil Code Section 1798.83, permits California residents to ask for and obtain, only once a year, but free of charge, information about the categories of personal information (if any) obtained as a result of your use of the Services that we have also disclosed to third parties for direct marketing purposes along with the names and addresses of all third parties to whom we have provided personal information in the preceding calendar year. If you are a California resident and you desire to make such a request, please submit your request in writing by submitting a request following this link: submit a request.
Further, if you are under 18 years of age, reside in California, and have a registered account with the Services, you may request the removal of data that you have made publically available on the Services. To request removal of such data, please contact us in writing by submitting a request following this link: submit a request and include the email address associated with your account, where the content at issue can be located on the Services, and a statement confirming that you reside in California. We will endeavor to make sure that within a reasonable time the data at issue is not thereafter publicly displayed on the Website. But, please be aware that the data may not be completely or comprehensively removable from the Services’ systems.
IX. OPTING OUT OF RECEIVING ELECTRONIC COMMUNICATIONS
Our Services are CAN-SPAM compliant. We do not currently send out any emails to anyone but in the event should this change in the future, any user who wants to stop receiving the electronic newsletters, marketing materials, or promotions, or any offers or other correspondence from NHN may opt out of the Services’ email list at any time by following the “Unsubscribe” instructions contained in any email you receive from NHN, or by submitting a request to NHN in writing via this link: submit a request and provide the email account which you wish to unsubscribe with the word “Unsubscribe” in the subject line.
X. “DO NOT TRACK” OR “DNT” SIGNALS
The Services do not respond to “DNT” or “Do Not Track” signals. We are awaiting the results of efforts by the policy community and the relevant industry to determine when such a response to “DNT” or “Do Not Track” signals will be appropriate and what form they should take.
XI. LENGTH OF PERSONAL INFORMATION STORAGE
When we have no ongoing or further legitimate business needs or legal requirements to process your personal information, we may either delete it, make it anonymous, or, if neither option is possible (because, for example, the information has been archived in backups), then we will properly store your personal information by isolating it from any further processing until its deletion becomes possible.
XII. DEACTIVATED OR TERMINATED ACCOUNT
Please be aware that even after your account is terminated or deleted, some or all of your information may still remain visible to others. A request to delete and/or termination of your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us. We are not able and/or obligated to remove any of your information from a third party platform. Moreover, please be aware that even after you delete your account or your account is terminated, your information may not be deleted in its entirety from our servers and servers of the third party with whom such information have been shared
NHN GLOBAL, INC.
Attn: Gaming Business
3530 WILSHIRE BLVD STE 1600
LOS ANGELES CA 90010